Global Mobility

Türkiye | Implementation Communiqué published on the foreign-source income exemption regime

Summary

Following the enactment of Law No. 7582, which introduced a 20-year income tax exemption for certain foreign-source income earned by individuals relocating to Türkiye, the Ministry of Treasury and Finance has now published the long-awaited Implementation Communiqué setting out the practical application rules of the regime.

The detail

As discussed in our previous alert, the exemption generally applies to individuals who become Turkish tax residents on or after 1 January 2026 and who have not been tax resident or domiciled in Türkiye during the preceding three calendar years. The Communiqué does not materially change the scope of the exemption but provides important guidance on eligibility, compliance requirements, and administrative procedures.

Mandatory exemption certificate application

The most significant clarification introduced by the Communiqué is the requirement for eligible individuals to obtain a “Foreign-Source Income and Gains Exemption Certificate” from the competent tax office.

To benefit from the exemption, applications must be submitted:

• By the end of the calendar year in which the individual becomes a Turkish tax resident; or
• By the end of February of the following year if Turkish tax residency commences during the last two months of the calendar year.

The Communiqué explicitly states that taxpayers who fail to submit the application within these deadlines will not be entitled to benefit from the exemption, even if all other eligibility conditions are met.

Additional clarifications

• The Communiqué also provides further practical guidance on the application of the regime. It confirms that prior Turkish tax liability arising solely from Turkish-source rental income, investment income, or capital gains will not prevent an individual from benefiting from the exemption. Conversely, individuals who had other forms of Turkish tax liability during the relevant three-year lookback period, such as employment, business, or professional income, will generally not qualify for the regime.
• In addition, the Communiqué clarifies that the tax authorities will make their own review of the applicants statuses and that exemption certificates may be revoked if it is subsequently determined that the statutory conditions were not satisfied. In such cases, previously exempt foreign-source income may become subject to Turkish taxation together with applicable penalties and late payment interest.

Key takeaway

While the Communiqué confirms the principles introduced by Law No. 7582, it adds a critical procedural requirement by making the exemption contingent upon a timely application for an exemption certificate. Individuals relocating to Türkiye and intending to rely on the foreign-source income exemption should carefully monitor the application deadlines, as missing the filing window may permanently eliminate access to the regime.

Contact us

For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Cumhur Dülger
Partner

Begüm Özdamar
Senior Consultant

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