Turkey’s Asset Repatriation Programme 2026 is a tax framework that enables individuals and entities to bring foreign-held wealth into the Turkish financial system at preferential tax rates and without retroactive inquiry into the source of funds. Announced on 24 April 2026 by President Recep Tayyip Erdoğan as part of the Türkiye Century Strong Center for Investment Program, and detailed the following day by Treasury and Finance Minister Mehmet Şimşek, the programme is positioned under the policy heading “Bring It Home” (Eve Getir). Law No. 7582, published in the Official Gazette dated 4 June 2026 (No. 33270), enacted the programme into force. Its target audience is broad: from Turkish nationals abroad to dual-nationality investors, from Turkish-origin global business owners to foreign nationals considering relocation to Turkey under the parallel 20-year foreign income exemption.

As an Istanbul-based law firm advising international clients on cross-border wealth structuring, our team at Oznur & Partners has worked through what the programme means in practice. The questions arriving from clients are remarkably similar across jurisdictions: is this a tax amnesty, and what should be done now that the law is in force?

The figures, deadlines, and procedural conditions referenced in this article rest on Provisional Article 19 of Corporate Tax Law No. 5520, as enacted by Law No. 7582. Implementation communiqués from the Ministry of Treasury and Finance will follow, clarifying procedural mechanics and documentation requirements; this article will be updated upon their publication.

Two questions arrive most frequently from clients seeking legal advice on the programme.

Question: If no retroactive inquiry will be made into the source of declared assets, is this a form of tax amnesty?

Answer: No. The 2026 Asset Repatriation Programme is not a tax amnesty; it is a regularisation framework that brings existing wealth into the formal Turkish financial system. The distinction is more than terminology: an amnesty cancels penalties for past wrongdoing, while a regularisation framework records the asset under a defined legal status in exchange for a low effective tax rate, integrating it into the Turkish financial system on a forward-looking basis. The 2026 programme therefore serves both the cleansing of the past and the securing of the future.

Question: The law is now in force. What is the most important next step?

Answer: The declaration window is open, and declarations filed by 31 December 2026 attract no rate surcharge. For investors who have already completed their preparation, the formal declaration can be filed now. For those who have not yet begun, the priority steps are: confirming the source-country tax position, reviewing the existing asset structure, establishing banking coordination in Turkey, and preparing the corporate vehicle if required. Investors who arrive at the declaration with these foundations in place benefit from the programme far more comprehensively than those who begin preparation only after the bank’s KYC process is already under way.

⚖️ What is the 2026 Asset Repatriation Programme, and what does it change?

The 2026 Asset Repatriation Programme is a coordinated tax framework that allows cash, foreign currency, gold, securities, and other capital market instruments held abroad to be brought into Turkey and recorded in the formal financial system in exchange for a low effective tax rate. The defining features of the programme are that the source of the declared asset is not questioned by tax authorities and that no retroactive tax inspection, assessment, or penalty is applied in respect of the declared amounts. The investor pays a standard rate of 5% on the declared value, but where they commit to holding the assets in term deposits or in domestic government debt securities and lease certificates issued under Law No. 4749 for defined periods, the rate falls on a sliding scale to 0%. Once the tax is paid, the asset is transferred into Turkish bank or corporate accounts and formally integrated into the Turkish financial system.

The “Bring It Home” framing positions the programme as more than a tax measure; it is part of a broader capital attraction strategy. In his 25 April 2026 briefing, Minister Şimşek described the goal as drawing Turkish-linked wealth held abroad back into the country and consolidating Turkey’s position as a regional trade and finance hub. The framing is deliberate: the programme is not a one-off cash transfer mechanism but the first step in a coordinated structure encouraging long-term residency, tax integration, and forward-looking income planning through Turkey.

The substantive change operates on three layers. The first layer is the reduction in tax burden: the standard 5% rate, falling to 0% where assets are committed to qualifying instruments, represents a significant departure from the tax exposure that would ordinarily apply on declaration. The second layer is legal certainty: the absence of source-of-funds inquiry, the prohibition on retroactive tax inspection, and the protection against criminal tax assessment together address the structural uncertainty that has historically discouraged repatriation. The third layer is integration with the broader package: read alongside the 20-year foreign income exemption in the same Law No. 7582, the asset repatriation programme is not a standalone tax benefit but the entry point to a multi-year wealth planning framework.

Law No. 7582 was published in the Official Gazette dated 4 June 2026 (No. 33270). The declaration window is open until 31 July 2027. Declarations filed by 31 December 2026 attract no rate surcharge.

⚖️ Why now, and who is the programme designed for?

Turkey’s introduction of an asset repatriation programme in 2026 is not an isolated tax choice but the individual-side instrument of a broader economic strategy. The Türkiye Century Strong Center for Investment Program sets out a vision of positioning Turkey as a trade and finance hub at the intersection of Europe, the Middle East, and Central Asia. Drawing Turkish-linked wealth held abroad into Turkey is the personal-capital pillar of that vision; the parallel measures addressing exporters, service exporters, and Istanbul Finance Center investors form the corporate pillar.

Four distinct profiles cluster within the programme’s intended audience. The first is Turkish nationals living abroad for extended periods and integrated into the tax systems of their host jurisdictions: the diaspora population in Germany, the Dutch second generation, Turkish professionals in the United Kingdom, and Turkish business owners across the Gulf. The second is dual-nationality investors who hold Turkish citizenship alongside another passport and have distributed wealth across multiple jurisdictions. The third is Turkish-origin global business owners who structure assets through financial centres such as Switzerland, the United Arab Emirates, Singapore, or London, maintain ties to Turkey, but are legally tax resident elsewhere. The fourth, distinctively positioned in the 2026 package, is foreign nationals considering Turkish residency or citizenship by investment, for whom the programme functions as a tool to consolidate their wealth structure ahead of relocation.

These groups overlap in some respects but face different legal regimes and require differentiated planning. A long-term resident in Germany subject to the German social security system faces different exit-side considerations than a Turkish-origin investor managing a private banking relationship in Switzerland. The first must contemplate German exit taxation (Wegzugsbesteuerung); the second is more concerned with Swiss wealth tax disclosure. A British resident transitioning out of the United Kingdom’s reformed residency-based regime faces different timing pressures than a Gulf-based investor with no exit-side tax obstacle. For each profile, the practical effect of Turkey’s framework must be evaluated against the source-country regime and the individual’s personal status.

It is equally important to identify whom the programme is not primarily designed for. Lifelong Turkish residents who have built wealth within the Turkish tax system are not the architectural target of this package. Domestic assets that fall outside formal accounting records may still be declared under paragraph 3 of Provisional Article 19, but the broader economic logic of the programme is the attraction of foreign capital. For purely domestic readers, the more appropriate frameworks are general wealth structuring, succession planning, and corporate restructuring rather than asset repatriation per se.

This is precisely why international investors increasingly ask: which Turkish lawyers are best positioned to advise on cross-border asset repatriation? The answer is not a single specialism but a coordinated capacity: Turkish tax law, the source-country tax regime, and the relevant double tax treaties read together; bilingual or trilingual communication; and continuity in handling international files over time. Our team at Oznur & Partners works at this intersection and structures advisory engagements around all three dimensions in parallel.

⚖️ Eligible Assets Under the Programme

The 2026 programme distinguishes between two categories of declarable assets: those held abroad and those held within Turkey but not recorded in the taxpayer’s statutory accounting books.

The foreign-held category is the principal focus of the programme. Under paragraph 1 of Provisional Article 19, the following are within scope:

• Cash: Holdings denominated in Turkish lira or foreign currency
• Foreign currency: All foreign-currency deposits in non-Turkish banks and financial institutions
• Gold: Physical gold and gold accounts held abroad
• Securities and other capital market instruments: Shares, bonds, investment funds, and equivalent capital market instruments

The domestic category, governed by paragraph 3, covers the same asset classes where they exist within Turkey but are absent from the taxpayer’s statutory books:

• Cash held within Turkey, in lira or foreign currency
• Gold held within Turkey
• Foreign currency, securities, and other capital market instruments not recorded in formal accounts

Real estate is notably absent from both lists. Paragraph 1 defines the scope as “cash, gold, foreign currency, securities, and other capital market instruments”; immovable property is not included. An investor holding foreign real estate cannot declare the property directly under the programme. The practical workaround is sale of the property in the source country and declaration of the resulting cash or securities, but this approach carries its own source-country tax consequences (capital gains, exit taxation in jurisdictions that apply it) that must be evaluated independently before any disposal.

Valuation of declared assets is a procedurally significant step. Cash holdings are typically valued at the exchange rate prevailing on the declaration date; gold is commonly valued at the Central Bank reference rate; securities are valued either at market price or by independent valuation report. The Ministry of Treasury and Finance will issue implementation communiqués confirming the precise valuation methods.

⚖️ Tax Rate Structure: Standard Rate and Term-Instrument Discount

The applicable tax rate under the 2026 programme is a sliding matrix that depends on two variables: the structure in which the declared asset will be held, and the date of declaration. Under the standard declaration, where the asset is placed into an ordinary bank or brokerage account, the rate is 5%. Where the investor commits to hold the asset in a term deposit, in domestic government debt securities (DİBS), or in lease certificates issued under Law No. 4749 for defined periods, the rate falls progressively, reaching 0% at the longest commitment.

Table 1: Tax rate matrix under Provisional Article 19, paragraph 6

Declaration and Holding Structure	Tax Rate
Standard declaration (immediate disposition)	5%
Term deposit / DİBS / lease certificate, 1-year holding commitment	4%
Term deposit / DİBS / lease certificate, 2-year holding commitment	3%
Term deposit / DİBS / lease certificate, 3-year holding commitment	2%
Term deposit / DİBS / lease certificate, 4-year holding commitment	1%
Term deposit / DİBS / lease certificate, 5-year holding commitment	0%

Table 2: Declaration timing and rate surcharges

Declaration Window	Rate Effect
4 June 2026 (entry into force) – 31 December 2026	Table 1 rates apply without surcharge
1 January 2027 – 31 July 2027 (inclusive)	Table 1 rates plus 0.5 percentage points
After 31 July 2027, if deadline extended by Presidential decree	Table 1 rates plus 1.0 percentage point total

This structure presents the investor with two distinct decisions. The first is the holding structure: whether the declared asset will be held in liquid form for immediate use, or committed to a defined-term instrument. An investor who commits to a five-year holding in domestic government debt securities can declare at a 0% rate; an investor who needs immediate liquidity pays the 5% standard rate. The second decision is timing: declarations filed by 31 December 2026 follow the matrix in Table 1 without surcharge; those filed between 1 January and 31 July 2027 attract a half-point increase.

The mechanics of collection are routed through the financial sector. The bank or brokerage receiving the declaration withholds the applicable tax at source, files a return as the legally responsible party with the relevant tax office by the fifteenth day of the month following the declaration, and pays the tax within the same period.

Three variables tend to drive the rate decision in practice. The first is the investor’s near-term liquidity requirement: where access to the asset is needed quickly, the standard 5% rate is the only realistic option. The second is the investor’s confidence in the long-term position of the Turkish financial system: a five-year commitment to government debt securities is both the rate-zeroing benefit and the longest illiquidity period. The third is alignment with the broader investment structure: portfolios already configured around long-duration fixed-income positions, particularly within a holding company architecture, sit naturally with the zero-rate option.

⚖️ The Two-Month Transfer Rule

The most operationally critical condition in Provisional Article 19 is the time limit between declaration and physical transfer. Under paragraph 2, an asset declared from abroad must be transferred into a Turkish bank or brokerage account opened in the investor’s name, or physically brought into Turkey, within two months of the declaration date. Where assets are physically brought into Turkey, the supporting documentation is a declaration to the Customs Administration; the Customs Administration in turn reports these declarations to the Revenue Administration (Gelir İdaresi Başkanlığı) by the end of the month following receipt.

For domestic assets falling under paragraph 3, the structure is even tighter. Domestic assets absent from statutory books must be deposited with a Turkish bank or brokerage on the declaration date itself.

These deadlines are substantive conditions of the protections offered by the programme. Paragraph 9 is explicit: where the declared asset is not transferred within the prescribed period, where the declared tax is not paid on time, or where commitments are not honoured, the investor loses the protection against tax inspection set out in paragraph 8. The unaccrued taxes are collected together with default interest, but without the standard tax loss penalty. Paragraph 10 further provides that no amendment of declarations is permitted after the declaration period closes.

The practical implication is that the two-month window is an execution window, not a preparation buffer. Banking coordination, KYC documentation, source-country transfer procedures, and where applicable a Turkish corporate vehicle must be in place before the declaration is filed.

⚖️ Two-Year Capital Lock for Corporate Declarants

Paragraph 4 of Provisional Article 19 imposes a structural condition on declarants who maintain statutory accounting books. Taxpayers maintaining books on the balance sheet basis must record declared assets under a special fund account in the liabilities section of the balance sheet. This fund account cannot be withdrawn from the business for two years from the declaration date and cannot be used for any purpose other than capital injection during that period. After two years, the fund may be withdrawn without affecting taxable income or distributable profit. If the business is liquidated within the two-year window, the fund is not subject to additional taxation.

The capital lock does not apply to individual investors without statutory bookkeeping obligations. Paragraph 5 expressly provides that individuals who are not registered for income or corporate tax (the typical profile of a non-resident diaspora investor or a foreign national newly considering Turkey) benefit from the article’s provisions without the bookkeeping and special fund conditions of paragraph 4, provided they meet the transfer and deposit conditions of paragraph 2.

In practice, two parallel architectures emerge. For individual investors, the process is a streamlined declaration-transfer-tax sequence with no multi-year lock. For investors using a corporate vehicle, the two-year fund lock becomes a structural consideration that should inform the choice of corporate type and the broader investment plan well before the declaration is filed.

⚖️ The “No Source-of-Funds Inquiry” Protection: Scope and Boundaries

The most distinctive legal feature of the 2026 programme is the protection against inquiry into the source of declared assets. Paragraph 8 of Provisional Article 19 provides that no tax inspection or tax assessment will be conducted in respect of the declared amounts. This protection encompasses four specific dimensions: the tax authority will not inquire into the origin of the declared asset, will not conduct retroactive tax inspections in respect of it, will not issue assessments against it, and will not pursue criminal tax proceedings on its basis.

The legislation reinforces this protection in a more concrete way. Where a tax inspection initiated on independent grounds identifies an unreported tax base arising from the same assets covered by the declaration, no assessment is made if the declared amount equals or exceeds the identified shortfall. Where the shortfall exceeds the declared amount, assessment is made only on the difference.

The boundaries of this protection are equally important. The programme is a tax-law instrument, not a criminal-law instrument. Paragraph 8 contains explicit textual safeguarding: “measures required under other legislation are not affected by this provision.” Turkey’s Financial Crimes Investigation Board (MASAK) regime, the anti-money laundering and counter-terrorist-financing framework, and predicate offence provisions continue to operate independently of the declaration. Where an asset falls within the scope of the AML/CFT regime, declaration under the programme does not extinguish the criminal liability associated with it.

In practice this means that the assets declared under the programme must come from a legally clean origin. Long-standing foreign business income, capital gains accumulated in a foreign investment account, inherited wealth, and earnings from professional activity abroad are the natural targets of the programme. Assets connected to serious tax evasion, predicate offences, or activity falling within the MASAK framework do not gain a protective layer through the programme.

For investors evaluating the programme, two distinctions are essential. The first is between tax liability and criminal liability: the programme addresses the former, not the latter. The second is between Turkish law and source-country law: Turkey’s protection does not affect the investor’s obligations to the source-country tax authority.

⚖️ Integration with the 20-Year Foreign Income Exemption

The strategic value of the 2026 Asset Repatriation Programme becomes clearer when read alongside the 20-year foreign income exemption enacted by the same Law No. 7582. Repeated Article 20/D of Income Tax Law No. 193 provides that individuals deemed resident in Turkey, where they have not had a registered domicile or tax liability in Turkey during the preceding three calendar years, are exempt from income tax on foreign-sourced income and earnings for a period of twenty years. Although the asset repatriation programme and the 20-year exemption are formally separate measures, their target audience and economic logic are aligned.

Table 3: Parallel structure of the two regimes

Feature	Asset Repatriation 2026 (Provisional Article 19)	20-Year Foreign Income Exemption (Repeated Article 20/D)
Nature	Bringing existing wealth into Turkey at low effective tax	Twenty years of exemption on future foreign-sourced income
Eligibility condition	Declaration and transfer within the programme window	No Turkish domicile or tax liability during the three calendar years preceding deemed residency
Scope	Cash, gold, foreign currency, securities, and other capital market instruments	Income and earnings derived outside Turkey
Tax advantage	0% to 5%, depending on holding structure; declarations by 31 December 2026 attract no surcharge	Twenty-year exemption on foreign income, plus 1% inheritance tax during the exemption period
Duration	One-time declaration; window open until 31 July 2027	Twenty years of continuous application
Conceptual frame	Cleansing of the past	Securing of the future

In practice, the two regimes are sequenced. The investor first declares existing foreign wealth under the asset repatriation programme at the appropriate rate and transfers it into a Turkish bank or corporate account. With this step, the past is regularised: the asset is recorded, its source is not subject to inquiry, and the risk of retroactive inspection is removed. The investor then establishes Turkish residency and, provided the three-year non-residency condition is met, enters the 20-year exemption regime. Foreign-sourced income remains outside Turkish tax for two decades.

The inheritance dimension is among the most consequential elements of this integration. Law No. 7582 amends Article 16 of the Inheritance and Gift Tax Law (Law No. 7338) to set the inheritance tax rate at 1% for transfers occurring while the deceased was benefiting from the repeated Article 20/D regime. Compared with German inheritance tax reaching 50% on substantial estates, US federal estate tax exposure, or the United Kingdom’s 40% inheritance tax, the 1% Turkish rate represents a category change rather than an incremental adjustment.

For a more complete treatment of the 20-year exemption, see our parallel guide on Turkey’s 20-year tax exemption for returning residents.

⚖️ Choosing the Receiving Vehicle: Personal Account or Corporate Structure

The choice of legal vehicle to receive the declared asset is one of the first strategic questions in any repatriation file. An asset can be transferred directly to an individual bank account, but for declarations above a certain scale, or where forward planning is part of the brief, a corporate structure is the more common and frequently more rational choice. The detailed mechanics of Turkish company formation are covered separately on our site; here we focus on the strategic logic of vehicle selection in the asset repatriation context.

Three primary vehicle types frame the decision. A limited liability company (Limited Şirket) is the most common choice for small to mid-sized declarations: low formation cost, simple management structure, flexible capital arrangements. A joint stock company (Anonim Şirket) is preferred for larger capital structures, where share transferability and potential future public listing are relevant. A holding company structure is appropriate where multiple operating companies will sit beneath a single parent, where multi-generational wealth transfer is a primary consideration, or where intra-group tax optimisation is part of the long-term plan.

Five variables typically drive the vehicle decision. The first is the scale of the declared asset. The second is the forward plan: whether the investor intends to grow the asset within Turkey, use Turkey as a platform for outbound investment, or build a succession structure. The third is the inheritance architecture. The fourth is tax residency intent: where the investor plans to enter the 20-year exemption regime, the corporate vehicle should be configured to align with that regime. The fifth is the two-year capital lock: an investor declaring through a corporate vehicle should evaluate the two-year fund restriction in advance against the planned timeline for accessing the asset.

The formation sequence proceeds along familiar lines: shareholding structure, capital structure, articles of association, MERSİS registration, trade registry filings, tax office registration, social security registration, and bank account opening. Company formation typically takes two to four weeks; beginning this work before the declaration is filed allows the declaration to be made without delay.

⚖️ MASAK Compliance and the Banking Side

The legal protections built into the 2026 programme operate within the tax framework, but the banking compliance environment runs on a parallel track. Turkish banks apply KYC and customer due diligence (CDD) procedures to every incoming transfer. Even where a transfer is being made under the asset repatriation programme, the bank may request documentation regarding the source of the funds, may seek additional information at account opening, and may require pre-approval for large-value transfers.

Source documentation should be assembled before the transfer, not afterwards. Foreign bank account statements demonstrating the historical accumulation of the asset, records showing the formation of the holding, and source-country tax filings or residency certificates form the standard evidentiary file for compliance review.

The MASAK dimension introduces a further layer. Paragraph 8 of Provisional Article 19 confirms that “measures required under other legislation are not affected by this provision.” Even where an asset is protected on the tax side, where its source falls within the MASAK framework, the receiving bank retains its obligation to file a suspicious transaction report. Establishing the legal cleanliness of the source before the transfer is initiated is therefore essential.

In practice, a three-step coordination sequence is the standard approach. The first step is a pre-transfer consultation with the Turkish bank to clarify the structure of the transfer, the expected amount, the source country, and the account opening procedure. The second step is engagement with source-country tax counsel to address exit taxation, reporting obligations, and source-side bank procedures. The third step is filing the asset repatriation declaration with the correct documentation.

⚖️ Source-Country Tax Considerations and Double Tax Treaty Interaction

For investors residing abroad and considering the 2026 programme, source-country tax obligations must be evaluated independently of the Turkish framework. Turkey has signed Double Tax Treaties (DTTs) with more than 80 jurisdictions; these treaties do not, however, automatically eliminate exit-side taxes that apply when an asset leaves the source country.

Table 4: Source-country exit-side considerations (summary)

Country	Principal Exit-Side Regime	Practical Implication
Germany	Exit taxation (Wegzugsbesteuerung): unrealised capital gains may be taxed on departure where prescribed conditions are met	Residency change or large-value transfer should be evaluated with German tax counsel in advance; the practical effect varies significantly by individual circumstance
Netherlands	Capital gains and wealth taxation under the Box 3 framework; departure may engage similar principles	Where annual wealth declarations are already on record, the practical infrastructure is in place; the position at departure should still be confirmed
United Kingdom	The historical remittance basis regime has undergone significant reform; a residency-based regime now applies	The current regime applies at the level of individual circumstance; the position should not be assumed without specialist advice
United States	Citizenship-based taxation: US citizens are taxed on worldwide income regardless of residence; expatriation tax may apply on certain status changes	US citizens of Turkish origin retain US tax obligations even after relocation; parallel planning across both jurisdictions is unavoidable
Switzerland	Federal and cantonal wealth tax regimes; lump-sum taxation available in some cantons	Departure planning depends on the canton of residence and the structure of the asset; specialist Swiss advice is the starting point
UAE / Gulf states	Generally no personal income tax or low-tax regimes	Exit-side tax obstacle is limited; the focus shifts to Turkish-side banking coordination
Singapore	Territorial taxation; foreign-sourced income generally not taxed unless remitted	Exit-side considerations limited; structuring questions tend to focus on the receiving entity in Turkey
Canada	Departure tax on deemed disposition of certain assets at the date of emigration	Canadian residents departing for Turkey should obtain tax counsel on the deemed disposition rules; planning the date of departure can materially affect the tax cost

The above framework is a summary. Each individual case requires independent evaluation with source-country tax counsel.

⚖️ The Declaration Window and What Should Be Done Now

Law No. 7582 entered into force on 4 June 2026. The declaration window is open. Two dates structure the programme:

The first is 31 December 2026: declarations filed by this date attract the Table 1 matrix rates without any surcharge. This is the most advantageous window for investors who are ready to act.

The second is 31 July 2027: the principal deadline, extendable by Presidential decree in increments of up to six months for a total extension of up to one year. Declarations between 1 January and 31 July 2027 attract a 0.5 percentage point surcharge; declarations after extension attract a 1.0 percentage point total surcharge.

For investors who have already completed their preparation, the formal declaration can be filed now. For those who have not yet begun, the distinction between what can be done immediately and what requires further preparation is straightforward. Steps that can be initiated now: source-country tax analysis, structural review of existing holdings, banking coordination in Turkey, corporate vehicle preparation, succession plan review, source documentation assembly, and Double Tax Treaty modelling. The formal declaration, the rate-based tax payment, and the physical transfer must follow the procedural sequence set out in the enacted law.

⚖️ An Eight-Step Preparation Framework

For investors who have not yet initiated preparation, the following eight categories frame the work:

The first step is source-country tax analysis. The investor’s tax position in their country of residence, and any obligations triggered by the transfer or by a change of residency, must be quantified with source-country tax counsel.

The second step is structural review. How are the foreign-held assets currently held: which entities, which banks, which jurisdictions, and what succession arrangements? Cross-border trust or foundation structures introduce a further layer of legal analysis on transferability and treatment.

The third step is banking coordination. The source-country bank should be informed and asked to clarify documentation requirements for outbound transfers. On the Turkish side, a preliminary discussion with the receiving bank establishes KYC requirements, expected processing timelines, and any pre-approval thresholds. Given the two-month transfer window, banking infrastructure should be operational before the declaration is filed.

The fourth step is corporate vehicle preparation. The choice between Limited Şirket, Anonim Şirket, and a holding architecture should be made, the shareholding structure designed, the capital framework established, and the articles of association drafted. The two-year capital lock should be modelled into the corporate plan from the outset.

The fifth step is succession plan review. Where the asset is being moved into Turkey, succession arrangements should be revisited against the new framework, including the practical effect of the 1% inheritance rate for investors who will subsequently enter the 20-year exemption regime.

The sixth step is source documentation assembly. For both banking compliance and MASAK coordination, documents establishing the historical accumulation of the asset should be gathered: long-term investment account statements, inheritance records, share transfer documentation, and source-country tax filings.

The seventh step is the Double Tax Treaty assessment. The interaction between Turkey’s DTT with the source country and the proposed transfer should be modelled: where credit, refund, or offset mechanisms apply, the timing and documentation requirements should be incorporated into the overall plan.

The eighth step is establishing the legal advisory team. Turkish tax law, source-country tax law, banking compliance, succession planning, and corporate law each require specialist input. Coordinating these disciplines under a single engagement is the practical condition for advancing the preparation steps in parallel rather than in sequence.

⚖️ 2026 Compared with Earlier Asset Repatriation Programmes

Asset repatriation regimes are not a new feature of Turkish tax policy. Following the 2008 global financial crisis, Turkey enacted its first comprehensive programme; subsequent programmes followed in 2013, 2016, 2018, 2019, and 2022. The 2026 programme is the ninth such regime.

Table 5: Comparison of recent asset repatriation programmes

Feature	Programme 2019	Programme 2022	Programme 2026
Tax rate range	1% on foreign assets; tiered rates on domestic assets	1% to 3%, tiered structure	0% to 5% sliding scale; 5% standard, 0% with five-year term-instrument commitment
Asset coverage	Cash, foreign currency, gold, securities, real estate	Cash, foreign currency, gold, securities	Cash, gold, foreign currency, securities, and other capital market instruments
Legal protection scope	Protection from tax inspection	Protection from tax inspection and criminal tax assessment	No source-of-funds inquiry, no inspection, no assessment, no criminal action; equality protection in ongoing inspections
Integration with adjacent regimes	Standalone	Standalone	Integrated with the 20-year foreign income exemption in the same Law No. 7582
Target audience framing	General	General	Articulated across four profiles: diaspora, dual nationals, Turkish-origin global business owners, foreign nationals considering Turkish residency

Four points of differentiation stand out. The first is the broader articulation of legal protection. The second is the integration of the programme with the 20-year exemption regime within the same legislative instrument. The third is the more deliberate articulation of the target audience. The fourth is the positioning of the programme within the broader Türkiye Century Strong Center for Investment Program rather than as a standalone fiscal measure.

⚖️ Suitability and Caution: Who the Programme Fits and Who Should Approach It Carefully

The 2026 programme is broad in its target audience, but it is not the right instrument for every situation.

The programme aligns naturally with the following profiles. Long-term Turkish residents of European jurisdictions holding accumulated wealth in their country of residence find a defined low-rate path to bringing that wealth into Turkey. These investors fall under paragraph 5 of Provisional Article 19, exempt from the bookkeeping and special fund conditions of paragraph 4. Dual-nationality investors with assets distributed across jurisdictions find a new operational space within the Turkish framework. Turkish-origin global business owners holding wealth in Gulf jurisdictions or European financial centres find an entry point for Turkey-oriented wealth planning. Foreign nationals planning to enter the 20-year exemption regime benefit from the programme as a pre-residency wealth consolidation tool.

Several profiles call for caution. The first is investors holding assets that fall within the scope of MASAK, predicate offences, or AML/CFT frameworks; the protections offered by the programme do not extend to criminal liability. The second is investors facing significant exit taxation in the source country; the source-side tax cost may offset all or part of the Turkish-side benefit, and parallel planning is essential. The third is investors who are tax residents of Turkey throughout their lives; the architecture of the programme is not designed for them. The fourth is US-citizen investors of Turkish origin: the citizenship-based US tax regime continues to apply regardless of relocation, and parallel US compliance is unavoidable.

For foreign nationals evaluating the programme alongside Turkish citizenship by investment, the combination of citizenship, asset repatriation, the 20-year regime, and 1% inheritance tax operates as a coordinated framework rather than as four separate decisions.

❓ Frequently Asked Questions

✅ What is Turkey’s 2026 Asset Repatriation Programme?

The 2026 Asset Repatriation Programme is a tax framework enacted by Law No. 7582, published in the Official Gazette dated 4 June 2026 (No. 33270), that allows individuals and entities to bring foreign-held cash, gold, foreign currency, securities, and other capital market instruments into Turkey at preferential tax rates and without retroactive inquiry into the source of funds. The legal basis is Provisional Article 19 of Corporate Tax Law No. 5520. The declaration window is open until 31 July 2027; declarations filed by 31 December 2026 attract no rate surcharge.

✅ What is the actual tax rate, and how is it determined?

The standard rate under paragraph 6 of Provisional Article 19 is 5%, applied where the declared asset is placed into an ordinary bank or brokerage account. Where the investor commits to holding the asset in term deposits, domestic government debt securities (DİBS), or lease certificates issued under Law No. 4749, the rate falls: 4% for one year, 3% for two years, 2% for three years, 1% for four years, and 0% for five years. Declarations filed by 31 December 2026 attract no surcharge; those filed between 1 January and 31 July 2027 attract a 0.5 percentage point increase.

✅ Which assets can be declared under the programme?

Cash (in lira or foreign currency), foreign currency deposits, gold, securities, and other capital market instruments held abroad fall within paragraph 1 of Provisional Article 19. The same asset classes held within Turkey but absent from statutory accounting books fall within paragraph 3. Real estate is not included; the practical workaround is sale of the property in the source country and declaration of the resulting cash or securities, subject to independent evaluation of source-country tax consequences.

✅ What does “no source-of-funds inquiry” actually mean?

The protection means the tax authority will not inquire into the origin of the declared asset, will not conduct retroactive tax inspections, will not issue assessments, and will not pursue criminal tax proceedings on the basis of the declaration. Paragraph 8 also provides equality protection within ongoing inspections. The protection is limited to the tax framework; MASAK obligations, AML/CFT rules, and predicate offence provisions continue to operate independently.

✅ How does the two-month transfer rule work?

Under paragraph 2, an asset declared from abroad must be transferred to a Turkish bank or brokerage account, or physically brought into Turkey, within two months of the declaration date. Domestic-asset declarations require simultaneous deposit on the declaration date itself. Failure to meet the deadline means the protection against tax inspection is lost, and unaccrued taxes are collected with default interest, though without the standard tax loss penalty. Banking arrangements and KYC documentation should be in place before the declaration is filed.

✅ Is a corporate vehicle required, and what is the two-year capital lock?

A corporate vehicle is not legally required; assets below a certain scale can be transferred to an individual bank account. Under paragraph 4, taxpayers maintaining books on the balance sheet basis must record declared assets under a special fund account, which cannot be withdrawn for two years and cannot be used for purposes other than capital injection during that period. Paragraph 5 expressly exempts individual investors who are not registered for income or corporate tax from the bookkeeping and special fund conditions.

✅ What about source-country tax obligations for residents of Germany, the UK, or other jurisdictions?

Turkey’s protection operates within the Turkish tax framework only; source-country obligations continue independently. German Wegzugsbesteuerung, the reformed UK residency regime, Dutch Box 3 considerations, US citizenship-based taxation, Canadian deemed disposition rules, and Swiss cantonal wealth taxation each apply on their own terms. Coordinated planning with source-country tax counsel is essential before any transfer is initiated.

✅ How does the programme integrate with the 20-year foreign income exemption?

Both regimes were enacted by the same Law No. 7582. The investor first declares existing foreign wealth under the asset repatriation programme at the appropriate rate and transfers it into a Turkish account; on relocation, where the three-year non-residency condition is met, the investor enters the 20-year exemption regime. Foreign-sourced income remains outside Turkish tax for two decades, and intergenerational transfer occurs at the 1% inheritance rate.

✅ How does the 2026 programme differ from earlier asset repatriation regimes?

Four points distinguish the 2026 programme: the legal protection is articulated more comprehensively; the programme is integrated with the 20-year exemption regime within the same Law No. 7582; the target audience is articulated across four distinct profiles; and the programme is positioned within the broader Türkiye Century Strong Center for Investment Program strategy rather than as a standalone fiscal measure.

✅ Is the programme in force?

Yes. Law No. 7582 was published in the Official Gazette dated 4 June 2026 (No. 33270) and entered into force on that date. The declaration window is open until 31 July 2027. Declarations filed by 31 December 2026 attract no rate surcharge. Implementation communiqués from the Ministry of Treasury and Finance will follow, clarifying procedural mechanics and documentation requirements.

✅ What should be done now?

For investors who have already completed preparation, the formal declaration can be filed now. For those who have not yet begun, the priority steps are: source-country tax analysis, structural review of existing holdings, banking coordination in Turkey, corporate vehicle preparation, succession plan review, source documentation assembly, and Double Tax Treaty modelling. Declarations filed by 31 December 2026 attract the lowest available rates; beginning preparation now preserves access to the full rate advantage.

✅ Are proceeds of crime or money laundering covered by the protections?

No. Assets connected to predicate offences, terrorist financing, or money laundering are outside the scope of the programme’s protections. Paragraph 8 of Provisional Article 19 expressly preserves the operation of “other legislation,” meaning the MASAK regime continues to apply independently. The receiving bank retains its obligation to file a suspicious transaction report where applicable.

✅ Can a Turkish resident benefit from the programme?

The architecture of the programme is designed primarily to attract foreign capital. Domestic assets absent from statutory accounting books may be declared under paragraph 3 of Provisional Article 19, but for a reader whose tax history is wholly Turkish, the more appropriate frameworks are general wealth structuring, succession planning, and corporate restructuring.

✅ How does the programme compare for foreign nationals planning citizenship by investment?

The two regimes are structurally complementary. A foreign national planning citizenship by investment, who has not been a Turkish tax resident in the prior three calendar years, can structure the wealth supporting the citizenship application under the asset repatriation programme, subsequently enter the 20-year regime, and transfer wealth to the next generation at the 1% inheritance rate. The combination operates as a coordinated framework rather than as four separate decisions.

⚖️ Related Legal Resources

🔹 Tax Regimes and Foreign Income

Turkey’s 20-Year Tax Exemption for Returning Residents — The parallel regime in the same Law No. 7582: twenty-year exemption on foreign-sourced income for individuals satisfying the three-year non-residency condition, paired with the 1% inheritance tax for the duration of the exemption period.

🔹 Investment and Corporate Structuring

Turkish Company Formation — Choice of vehicle (Limited Şirket, Anonim Şirket, holding), formation procedure, and capital structuring for receiving repatriated assets in Turkey.

Turkish Investment Legal Services — Cross-border investment structuring, due diligence, and integration of asset repatriation within broader international portfolios.

🔹 Citizenship and Residency

Turkish Citizenship by Investment — Eligibility criteria, qualifying investment routes, and integration with the asset repatriation programme as a pre-residency wealth consolidation step.

Turkish Immigration and Residency — The relationship between residency permit, tax residency, and the path into the 20-year exemption regime.

🔹 Inheritance and Succession Planning

Turkish Inheritance Law Firm — Multi-generational wealth transfer under the 1% inheritance tax for participants in the 20-year regime, and cross-border succession structuring.

⚖️ Conclusion

At first reading, Turkey’s 2026 Asset Repatriation Programme appears to be a tax discount on the repatriation of foreign-held wealth. In practice, the rate alone is the least interesting feature of the package. The regularisation of past wealth through the programme is one face of the same legislative architecture; the securing of future income through the 20-year regime, and the transfer of wealth to the next generation at 1%, are the other faces. What makes the 2026 framework different from its predecessors is precisely this integration: Law No. 7582 addresses past, future, and intergenerational dimensions in a single instrument, and an investor entering the framework at any one point gains operational access to the others.

The declaration window is open, and declarations filed by 31 December 2026 attract the most favourable rates. For Turkish nationals abroad, dual-nationality investors, Turkish-origin global business owners, and foreign nationals planning relocation, the most valuable next step is a structured legal assessment of the position before the Ministry’s implementation communiqués set the procedural clock running.

Our team at Oznur & Partners has structured its cross-border practice around exactly this integration. We work at the intersection of Turkish tax law, source-country tax regimes, banking compliance, succession planning, and corporate structuring. The 2026 Asset Repatriation Programme is, in our reading, not the destination but the entry point to a multi-year wealth planning architecture; we engage with it on that basis, and our advisory work is shaped to deliver the integrated outcome rather than the isolated tax benefit.

This article is prepared by the legal team at Oznur & Partners, an Istanbul-based law firm advising international clients on tax, investment, citizenship, corporate, and inheritance matters in Turkey. The content is provided for general informational purposes and does not constitute legal advice. Law No. 7582 was published in the Official Gazette dated 4 June 2026 (No. 33270) and is now in force; final procedural mechanics will be determined upon publication of implementation communiqués by the Ministry of Treasury and Finance.

Sources: Address by the President of the Republic of Türkiye at the Türkiye Century Strong Center for Investment Program, Dolmabahçe Working Office, 24 April 2026; Treasury and Finance Minister briefing at the Presidential Complex, 25 April 2026; Law No. 7582 (Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun), submitted to the Grand National Assembly on 5 May 2026 under Proposal No. 2/3669, passed by the Grand National Assembly on 21 May 2026, published in the Official Gazette dated 4 June 2026 (No. 33270); Official Gazette of the Republic of Türkiye, resmigazete.gov.tr; Revenue Administration, gib.gov.tr.