INTRODUCTION

The most common route to Turkish citizenship by investment, and by far the most widely used in practice, is the acquisition of real estate. Under Article 12 of the Turkish Citizenship Law No. 5901 and Article 20 of the Regulation on its Implementation, a foreign investor who purchases real estate worth at least USD 400,000 (or its equivalent in another currency), and who registers an annotation in the land registry undertaking not to sell it for three years, may apply for Turkish citizenship by way of the exceptional route, provided that the remaining statutory conditions are also met.

Declaring a price of USD 400,000 or more in the official deed, or paying that sum, is not on its own sufficient. Under the legislation of the General Directorate of Land Registry and Cadastre (“TKGM”), three figures must each independently meet the statutory threshold: the price stated in the official deed; the amount transferred, as evidenced by the bank transfer and the Foreign Currency Purchase Certificate (“DAB”); and the actual market value of the property.

The mechanism by which TKGM establishes that market value is therefore central. Under TKGM Circulars No. 2024/2 and No. 2024/4, the previous valuation report procedure has been replaced by a new mechanism: valuation reports are prepared by GEDAŞ Gayrimenkul Değerleme A.Ş., the valuation company designated by TKGM for citizenship-related acquisitions, and on the basis of those reports a Certificate of Determination of the Amount Constituting the Basis for the Acquisition of Citizenship by Way of Real Estate Acquisition (“TTB”) is generated electronically through the TADEBİS and WebTapu systems. The purpose is to render the investment amount objective and verifiable.

TKGM has, however, carved out an exception for transactions carried out by certain corporate structures. That TTB confirmation is not required where a Real Estate Investment Trust (“REIT”) is a party to the sale is among the most significant features of current practice. This article examines the legal character of the TTB requirement, the rejection criteria tightened after 13 June 2024, and the rationale for and operation of the REIT exemption.

1. HOW IS THE MINIMUM INVESTMENT REQUIREMENT OF USD 400,000 ASSESSED?

Under Circulars No. 2024/2 and No. 2024/4, the minimum investment requirement of USD 400,000 (or its equivalent in another currency) is assessed as follows.

A.Three-Way Verification of the Investment Amount

Compliance is not established from a single document. Each of the following three elements must independently meet the amount required by the Regulation on the Implementation of the Turkish Citizenship Law as in force on the date of acquisition:

The Price Stated in the Official Deed

The sale prices declared in the official deed, or the aggregate of the prices set out in the promise-to-sell agreement.

Transfer of the Purchase Price

The aggregate of the transfers evidenced by bank payment receipts and the DAB.

The Value Stated in the TTB

The valuation result submitted through the Real Estate Valuation Information System (TADEBİS).

B.The TTB Requirement

Valuation reports are prepared by GEDAŞ and transmitted electronically to the TAKBİS/WebTapu system through TADEBİS. Documents submitted in hard copy are not processed. A TTB is valid for six months from its date of issue.

C. Purpose and Consequences

The purpose of this assessment is to prevent property from being presented above its actual value in order to abuse the citizenship route, and to confirm the investment requirement against objective data. For applications made after 13 June 2024, where the amount stated in the TTB falls below USD 400,000 the application is refused without further assessment. As set out below, sales by public institutions and by REITs are exempt from TTB confirmation.

II. WHY IS A VALUATION REPORT NOT REQUIRED WHERE THE PROPERTY IS PURCHASED FROM A REIT?

Although a valuation report and the resulting TTB confirmation are required as a general rule, sales to which a REIT is a party are exempt. That exemption follows from the Capital Markets Board (“CMB”) supervisory regime and the financial transparency standards to which REITs are subject.

which REITs are subject.

A.Legal Background

Under Article 12 of Law No. 5901 and Article 20(2)(b) of the Implementing Regulation, a foreigner who acquires property held under condominium ownership or construction servitude worth at least USD 400,000, or who executes a promise-to-sell agreement in that amount, may apply for Turkish citizenship by way of the exceptional route. Under Circulars No. 2024/2 and No. 2024/4, verification of the investment amount is carried out through the TTB issued via GEDAŞ and the TADEBİS system.

B.The Basis of the Exemption

Under Circular No. 2024/4, TTB confirmation is not required in sale or promise-to-sell transactions to which public institutions, their affiliates or REITs are a party. The grounds for this exemption are as follows.

CMB Supervision and Transparency

REITs are capital markets institutions subject to CMB regulation. The market values of the properties in a REIT’s portfolio are determined periodically by independent valuation firms licensed by the CMB, reported, and disclosed to the public.

Institutional Verification and Reliable Pricing

The risk of artificial or fictitious pricing that can arise in individual sales is substantially mitigated in transactions involving REITs, given the corporate and regulatory oversight to which they are subject. Because sale prices are fixed by official accounting and financial reporting records, TKGM has not considered a further valuation necessary.

Faster Transactions

Procedural steps such as the six-month validity period of the TTB and the TADEBİS application process do not apply to transactions benefiting from the exemption, saving the investor both time and administrative burden.

C.Points to Note

TKGM’s Authority to Require a TTB of Its Own Motion

Although exemption is the rule, the TKGM Department of Foreign Affairs reserves the right to require a TTB in transactions involving REITs as well, in exceptional cases where it considers this necessary.

Requirement to Provide Documentary Evidence of Payment

The exemption covers only verification of the valuation report. The DAB and the bank transfer receipts showing a purchase price of at least USD 400,000 must still be submitted.

The Three-Year Undertaking Not to Sell

The three-year non-sale annotation in the land registry, or the equivalent undertaking not to transfer in a promise to sell, applies to sales by REITs in exactly the same way.

III. WHY IS THE VALUATION REPORT TREATED DIFFERENTLY IN TRANSACTIONS INVOLVING REITs?

Under the Regulation on the Implementation of the Turkish Citizenship Law, the governing principle is that the sale price and the investment amount (at least USD 400,000) be verified transparently, genuinely and objectively. As a rule, that verification is carried out through the TTB prepared on the basis of a GEDAŞ valuation report.

Under Circular No. 2024/4, however, TTB confirmation is not required in sale transactions to which a REIT is a party, and such acquisitions are assessed differently. The grounds for this treatment are as follows.

A.Public Supervision under Capital Markets Legislation

REITs are subject to CMB regulation and to close public supervision. The values of the properties and projects in their portfolios are already determined periodically by CMB-licensed independent valuation firms and disclosed to the public.

B.No Need for a Second Valuation

Because prices in REIT portfolios are formed within a transparent and auditable market mechanism secured by legislation, TKGM sees no need to require a further TTB through GEDAŞ or an additional valuation report. The point is not that the value goes unsupervised, but that a value which has already passed corporate and regulatory scrutiny should not be subjected to duplicative procedure.

The exemption is a rule, not a guarantee. Under Circular No. 2024/4, the TKGM Department of Foreign Affairs retains the discretion to require a TTB in transactions involving REITs in specific cases where it considers this necessary.

IV. WHERE PROPERTY IS ACQUIRED FROM A REIT, DOES THE USD 400,000 REQUIREMENT CEASE TO APPLY?

No, it does not. Purchasing property from a project carried out by a REIT does not remove the minimum investment of at least USD 400,000 (or its equivalent in another currency) required under the Regulation on the Implementation of the Turkish Citizenship Law. Property acquired from a REIT must meet that threshold in full if it is to support a citizenship application. What differs is not the investment requirement or its amount, but the administrative method by which the amount is verified.

A.Standard Purchases

In ordinary practice, a TTB based on a GEDAŞ valuation report must be obtained and submitted through WebTapu/TAKBİS in order to confirm the sale price and the investment amount.

B. Transactions Involving REITs (the TTB Exemption)

Under Circular No. 2024/4, obtaining a TTB and verifying the amount on that basis is, as a rule, not required where a REIT is a party to the sale. Because REITs are supervised by the CMB and, by virtue of their transparent corporate structure, their portfolio values are subject to public scrutiny, TKGM does not impose the TTB requirement in addition.

The exemption does not mean that the citizenship process will be approved automatically. Under the same Circular, the TKGM Department of Foreign Affairs retains the power to require a TTB in transactions involving REITs where it considers this necessary.

V. WHAT SHOULD INVESTORS PAY ATTENTION TO?

Acquiring Turkish citizenship through real estate engages the legislation of several public bodies at once. In meeting the minimum investment of USD 400,000 required under the Turkish Citizenship Law No. 5901 and the Implementing Regulation, the following should be assessed in full.

A.Three-Way Compliance

The price declared in the official deed, the amount of the bank transfer receipts together with the DAB, and the appraisal value stated in the TTB must each independently meet the threshold of USD 400,000 (or its equivalent in another currency).

B.The TTB and the GEDAŞ Valuation Report

Since 4 March 2024, valuation reports must be issued by GEDAŞ Gayrimenkul Değerleme A.Ş. and the TTB generated through the TADEBİS/WebTapu system. Reports or certificates delivered in hard copy are invalid. A TTB is valid for six months. For transactions after 13 June 2024, an application will be refused without further assessment if the amount stated in the TTB falls below the required threshold.

C. The Nature of the Property and Undeveloped Land

Any type of property may be acquired — a residence, a workplace, a plot of land or a field. Where undeveloped property such as a plot or a field is acquired, however, the purchaser must, within two years, develop a project appropriate to the nature of the property and submit it for the approval of the relevant Ministry, failing which the property becomes subject to the liquidation provisions.

D. Statutory Restrictions and Encumbrances

A foreign natural person may not acquire more than 30 hectares in total nationwide, nor more than 10% of the privately owned surface area of any given district. The property must not lie within a military prohibited zone or a security zone; in a special security zone, the permission of the Governorship is required. Encumbrances on the title, such as attachments and mortgages, should also be checked before the transaction.

E. The Seller’s Legal Status and the Transfer of Title

Title passes only by official deed executed before a Land Registry Directorate; a notarised promise to sell does not by itself transfer ownership. Where the purchaser is a Turkish company with foreign capital, the permission of the Governorship (Provincial Directorate of Planning and Coordination) must be obtained before the land registry transaction.

F. Method of Payment and the DAB

The purchase price must be transferred through banking channels, and the bank must issue a Foreign Currency Purchase Certificate (DAB) in respect of the currency exchanged, transmitted through the registered electronic mail system (KEP).

G.The Three-Year Annotation and the Order of Steps

An annotation is entered in the land registry recording that the property was acquired for citizenship purposes and will not be sold for three years. Once the Land Registry Directorate has issued the Certificate of Determination of Real Estate Investment (“Taşınmaz Yatırımı Tespit Belgesi”), an application is made to the Presidency of Migration Management for a short-term residence permit for citizenship purposes under Article 31(1)(j) of Law No. 6458, followed by the citizenship application to the Directorate General of Civil Registration and Nationality.

CONCLUSION

The purpose of the valuation and TTB requirement in the acquisition of Turkish citizenship through real estate is to prevent collusive sales and the artificial inflation of prices, and to verify that the foreign investor has in fact brought into the country the minimum capital envisaged by the legislation. TKGM’s position since 13 June 2024 — refusing an application outright where the amount stated in the TTB falls below USD 400,000 — demonstrates how central that verification mechanism is.

The reason TTB confirmation is not required where a REIT is a party to the sale is not that investors are being granted an arbitrary privilege. REITs are supervised by the Capital Markets Board, carry public disclosure obligations, and hold portfolios that are appraised at regular intervals by independent valuation firms. Sale prices in such transactions are therefore already treated as having passed corporate and regulatory scrutiny, and no second TTB is needed for the same property. It should be remembered, however, that the TKGM Department of Foreign Affairs may require a TTB of its own motion in sales by REITs where it considers this necessary.

Exemption from the TTB procedure does not remove the other ownership-related and administrative conditions of the citizenship process:

The undertaking, given before the Land Registry Directorate, not to sell the property for three years;
The obtaining of the Certificate of Determination of Real Estate Investment (the certificate of conformity) issued by the land registry administration;
The establishment, before the Presidency of Migration Management, of a short-term residence permit for citizenship purposes under Article 31(1)(j) of Law No. 6458;
The completion of the final citizenship application through the Directorate General of Civil Registration and Nationality.

Each of these successive administrative steps must be completed in full. Technical matters such as the obligation to develop a project within two years where the property acquired is undeveloped land, or the state of any encumbrances over the property, also bear directly on the process. Investors intending to apply for Turkish citizenship through the acquisition of real estate should therefore assess their investment not solely by reference to the sale price, but against all of the technical and administrative requirements imposed by Turkish legislation on foreigners and on the land registry; and the process should be conducted under the guidance of lawyers specialised in the field, so that any potential loss of rights is avoided. The Celiktas Law Firm team provides professional legal support in matters concerning the acquisition of Turkish citizenship through the acquisition of real estate.

SOURCES

Turkish Citizenship Law No. 5901, Article 12.

Regulation on the Implementation of the Turkish Citizenship Law, Articles 20 and 20(2)(b).

Law No. 6458 on Foreigners and International Protection, Article 31(1)(j).

General Directorate of Land Registry and Cadastre (TKGM), Circular No. 2024/2.

General Directorate of Land Registry and Cadastre (TKGM), Circular No. 2024/4, dated 13.06.2024 — https://www.tkgm.gov.tr/yabancii-db/turk-vatandasligi-kanunu-uygulama-yonetmeligi-hk-20244-sayili-genelge

Legislation on the Acquisition of Real Estate for Citizenship Purposes — (TKGM) https://www.tkgm.gov.tr/yabancii-db/vatandaslik-icin-tasinmaz-edinimi-hakkinda-mevzuat

This article reflects the legislation and administrative practice in force as at the date of publication (August 2026). It is provided for general information only and does not constitute legal advice.