US Citizens in Turkey remain taxable by the US on worldwide income even after relocating, because the US taxes by citizenship, not residence. This single fact reshapes every financial decision an American makes about moving to Turkey, and it is the one most people discover too late.

When Americans research Turkey’s tax landscape, they usually arrive through one door: the country’s generous 20-year exemption on foreign income. The conclusion feels obvious. If Turkey stops taxing foreign earnings, then moving there means paying no tax at all. For a German, a Brit, or a Turkish returnee, that instinct is broadly correct. For a US citizen, it is a trap, and the reason is structural rather than a matter of paperwork.

The United States is one of only two countries in the world (Eritrea is the other) that taxes its citizens on worldwide income regardless of where they live. An American in Istanbul, Bodrum, or Antalya owes the IRS the same annual reporting as an American in Ohio. Turkey’s exemption removes the Turkish layer of tax. It does nothing to the US layer, which continues in full and in parallel.

This is precisely the point where a fast, intuitive judgment (“no Turkish tax means no tax”) leads to an expensive error. The slower, more accurate picture is that a US citizen relocating to Turkey faces two tax systems at once, one that switches off and one that does not. What actually happens to an American’s taxes after the move to Turkey? Turkish income tax on foreign-source income drops to zero under the exemption, while US federal tax, plus FBAR and FATCA reporting, continues without interruption. Both statements are true simultaneously, and planning only works once both are held in view.

The questions that follow are the ones sophisticated Americans actually ask before they commit. Which is more valuable for a US citizen, Turkey’s exemption or the US relief mechanisms that offset double taxation? The honest answer is that the US mechanisms usually matter more, because they are what stand between an American and a full US tax bill. And how much US tax does an American living in Turkey genuinely avoid? Less than they hope on investment income, close to everything on modest earned income, and the gap between those two outcomes is where good planning earns its fee.

This guide, prepared by Turkish lawyers who coordinate regularly with US expatriate tax specialists, gives an accurate and unvarnished account of what US citizenship means when you move to Turkey. It covers citizenship-based taxation, the FEIE and Foreign Tax Credit, FBAR and FATCA reporting, self-employment tax, the PFIC trap, and the exit tax that governs renunciation.

⚖️ Do US Citizens Really Still Pay US Tax After Moving to Turkey?

Yes. Unless a US citizen formally renounces citizenship, US worldwide taxation continues no matter where they live, including Turkey. Moving abroad changes where you sleep, not who taxes you. The IRS treats a US citizen in Turkey exactly as it treats one in California, with the same obligation to file and report every year.

The mechanism is citizenship-based taxation. Under the US Internal Revenue Code, all US citizens and green card holders are US taxpayers by virtue of their status, not their address. A US citizen living anywhere in Turkey is required to file a US federal return (Form 1040) every year, report worldwide income from every country, disclose foreign financial accounts above set thresholds, and pay US tax on any income that is not excluded or credited by a specific mechanism.

Green card holders sit in the same position. A US permanent resident is treated as a US person for tax purposes for as long as the green card is held. Establishing Turkish tax residency does not switch that off. Only surrendering the green card does, and for long-term holders that step can trigger its own exit tax consequences.

The affected population is larger than most people assume. It includes US-born Americans relocating to Turkey, naturalized citizens who later move back, Turkish-American dual nationals (one of the larger US expatriate communities linked to Europe), and green card holders of any nationality living in the country. Who exactly carries this obligation? Anyone who holds US citizenship or a US green card, regardless of a second passport, and regardless of how many years they have lived outside the United States.

Here is where loss aversion is useful rather than harmful. The prospect of continued US tax feels like a loss, so the temptation is to look away from it. But the real loss is not the tax; it is the penalty exposure and lost planning opportunities that follow from pretending the obligation is not there. The Americans who do best in Turkey are the ones who accept the US layer early and plan around it, rather than the ones who hope it disappears at the airport.

⚖️ Does Turkey’s 20-Year Exemption Help US Citizens at All?

It helps, but far less than it helps citizens of other countries, and understanding why is the single most valuable thing on this page. Turkey’s 20-year foreign income tax exemption removes Turkish tax on foreign-source income. For most nationalities that means the tax on that income genuinely goes to zero. For a US citizen, the exemption creates a different and slightly perverse result.

The problem is the Foreign Tax Credit. The US offsets double taxation by letting citizens credit foreign income tax paid against their US tax bill. That credit is the main tool that keeps Americans abroad from being taxed twice. But a credit only works when there is a foreign tax to credit. Turkey’s exemption sets the Turkish tax to zero, which means there is nothing to credit, which means the full US tax bill stands.

Read slowly, because the logic inverts intuition. For a German or a Turkish citizen, zero Turkish tax is pure benefit. For an American, zero Turkish tax can quietly remove the very credit that would otherwise have reduced US tax. The exemption that helps everyone else does not harm the American, but it fails to help in the way they expect, and it leaves the US bill fully intact on most categories of income.

The table below makes the asymmetry concrete. It compares three residents of Turkey with identical foreign income, each benefiting from the same 20-year exemption.

Resident of Turkey	Turkish tax on foreign income	Home-country tax	Net result
German citizen	0% (exemption)	None on foreign income once non-resident	Pays zero
Turkish citizen	0% (exemption)	None on qualifying foreign income	Pays zero
US citizen	0% (exemption)	Full US tax at standard rates	Pays full US tax

There is one important exception that runs the other way. If a US citizen earns income that Turkey’s exemption does not cover, such as Turkish-source rental income or dividends from a Turkish company, and Turkey taxes that income at standard rates, then the Turkish tax paid becomes creditable against the US bill on those same items. In other words, the Foreign Tax Credit returns to life exactly where the exemption does not reach. This is a recurring theme in US-Turkey planning: the exemption and the credit protect different income, and the skill lies in knowing which shield covers which asset.

⚖️ The US-Turkey Tax Treaty and Its Limited Protection for Americans

The US-Turkey double tax treaty protects many residents of Turkey from double taxation, but a special clause strips most of that protection away from US citizens specifically. The treaty was signed on 28 March 1996 and entered into force on 19 December 1997. On paper it allocates taxing rights on dividends, interest, royalties, capital gains, employment income, and pensions between the two countries.

The catch is the savings clause in Article 1(5). In essence it states that the United States may tax its own citizens as if the treaty had never come into force. This clause appears in every US tax treaty, and its effect is blunt. A US citizen cannot use the US-Turkey tax treaty to escape US tax on income the US would otherwise tax. The treaty’s double-tax relief still shields non-US-citizen residents of Turkey, but for Americans the protection survives only in narrow, carved-out situations.

Some carve-outs do exist. Certain treaty articles continue to protect US citizens even under the savings clause, including the relief-from-double-taxation article that underpins the Foreign Tax Credit. But the core protection, the one that would prevent the US from taxing a citizen on foreign-source income, is not among them. For practical purposes, the treaty is a tool for reducing Turkish tax and coordinating credits, not a shield against the IRS.

The table below summarizes how the main income categories are treated, and where the savings clause bites.

Income type	Treaty allocation	Effect on US citizens
Dividends	Residence country plus limited source withholding	US taxes; Turkish withholding credited
Interest	Residence country plus limited source withholding	US taxes; some withholding credited
Capital gains on shares	Residence country	Savings clause applies, US taxes regardless
Employment income	Where work is performed	Savings clause applies; FEIE helps partially
Private pensions	Residence country	Savings clause applies, US taxes

⚖️ The Two Mechanisms That Actually Lower Your US Tax

For US citizens in Turkey, two US-law mechanisms do the real work of reducing US tax: the Foreign Earned Income Exclusion and the Foreign Tax Credit. Neither comes from Turkey, and neither is automatic. They are the levers an American pulls to stop the US tax bill from landing in full.

The Foreign Earned Income Exclusion (FEIE), claimed on Form 2555, lets qualifying Americans abroad exclude a band of foreign earned income from US federal income tax. As of the 2025 tax year the exclusion is approximately 130,000 US dollars (it was 126,500 in 2024 and is adjusted annually for inflation). The word that governs everything here is “earned.” FEIE covers wages and self-employment income only. It does not touch dividends, interest, capital gains, rental income, or pension income, which are the categories most retirees and investors care about.

Qualifying for FEIE requires passing one of two tests: the Bona Fide Residence Test, which asks whether you are a genuine resident of Turkey for an uninterrupted period covering a full tax year, or the Physical Presence Test, which asks whether you were physically present in a foreign country for at least 330 full days in a twelve-month window. Living in Turkey for more than 183 days a year, which is also the threshold for establishing Turkish tax residency, clears both comfortably. The IRS explains the exclusion and its qualifying tests on its own Foreign Earned Income Exclusion guidance.

The Foreign Tax Credit (FTC), claimed on Form 1116, credits foreign income tax paid against US tax on the same income. Why does the credit so often fail to help Americans in Turkey? Because Turkey’s 20-year exemption sets the Turkish tax to zero, and a credit of zero foreign tax offsets nothing. The FTC is powerful in high-tax countries and largely idle in Turkey, except on the Turkish-source income the exemption does not cover.

The net picture, income type by income type, is where the two mechanisms show their limits.

Income type	Turkish tax	Relief available	Net US position
Foreign earned income up to the FEIE limit	0% (exemption)	FEIE	Zero
Foreign earned income above the FEIE limit	0% (exemption)	None on the excess	US rates apply
Foreign dividends and capital gains	0% (exemption)	No FTC (zero Turkish tax)	US rates apply
Turkish-source rental or dividends	Standard Turkish rates	FTC on the Turkish portion	Reduced double tax

The summary is simple to state and easy to forget. For earned income within the FEIE band, Turkey’s exemption and the FEIE together produce genuine zero tax on both sides. Above that band, and across all passive and investment income, the US bill stands. An American whose wealth sits in a portfolio should expect to keep paying the IRS; an American who earns a moderate salary abroad may pay almost nothing.

⚖️ Can I Keep a Turkish Bank Account Without the IRS Knowing?

No. Turkish banks report US-citizen accounts to Turkish authorities, who share the information with the IRS, so a Turkish account is visible to the US whether or not you disclose it. The realistic question is not whether the IRS will know, but whether your own filings match what the bank already reported. This is the reporting layer, and it is separate from whether you owe any tax at all.

The FBAR, filed as FinCEN Form 114, requires reporting all foreign financial accounts if their combined value exceeded 10,000 US dollars at any point during the calendar year. The scope is broad: Turkish bank accounts, brokerage and investment accounts, and even balances held with services like Wise or Payoneer. The deadline is 15 April, with an automatic extension to 15 October. Note that the FBAR is a report, not a tax; you can owe zero tax and still be required to file it. The IRS sets out the requirement on its Report of Foreign Bank and Financial Accounts page.

The penalties are where loss aversion becomes a rational guide rather than a bias. A non-willful violation can draw a penalty of up to 10,000 US dollars, and exactly how that figure is calculated has been the subject of significant litigation in recent years. A willful violation is far heavier, reaching the greater of 100,000 US dollars or half the account balance, with potential criminal exposure on top. Against penalties of that size, the cost of simply filing a straightforward form is trivial. The asymmetry is the entire point: the downside of not filing dwarfs the effort of filing.

FATCA reporting, on Form 8938, is a separate obligation attached to the Form 1040. It applies above higher thresholds. For taxpayers living outside the US, the trigger is 200,000 US dollars at year-end or 300,000 at any time during the year for single filers, and 400,000 at year-end or 600,000 at any time for those married filing jointly. Form 8938 and the FBAR overlap but neither replaces the other; when both apply, both must be filed.

Turkey is a FATCA partner jurisdiction, which is why the “will they know” question is already settled. Turkish financial institutions identify US-person account holders and report them under the bilateral framework. Which filing covers which account? The FBAR covers accounts you own or control once the 10,000 dollar aggregate is crossed, while Form 8938 covers a broader set of specified foreign assets once the higher income-tax-return thresholds are met, and many Americans in Turkey must file both.

⚖️ Self-Employment Tax and the US-Turkey Totalization Agreement

Self-employed Americans in Turkey face a US tax that the FEIE does not touch: Self-Employment Tax at 15.3%. This is the item that most surprises freelancers and consultants who assumed the FEIE wiped out everything. The FEIE eliminates income tax on excluded earnings; it does not eliminate the Social Security and Medicare component that self-employment carries.

The mechanics are worth stating plainly. Self-Employment Tax runs at 15.3% on net self-employment income up to the Social Security wage base (approximately 176,100 US dollars for 2025), with a 2.9% Medicare component above that. A US freelancer earning 100,000 dollars in Turkey might owe zero income tax after the FEIE and still owe roughly 14,000 dollars in Self-Employment Tax. That is a recurring annual cost, not a one-time surprise, and it deserves a place in any relocation budget.

Relief may come from the US-Turkey Social Security Totalization Agreement, which entered into force on 1 May 2005. Under a totalization agreement, a worker is generally subject to social security tax in only one country, the one where the work is genuinely covered. A US citizen employed by a Turkish employer and paying into Turkish social security (SGK) generally does not also pay US Self-Employment Tax. A self-employed American whose work is covered by the Turkish system may likewise be exempt from the US charge.

The determining question is factual rather than formulaic. Whether a self-employed American, or one employed by a non-Turkish company, falls under the Turkish or the US social security system depends on the specific arrangement. Where the agreement does exempt you, the saving is substantial, potentially in the range of 10,000 to 25,000 dollars a year for higher-earning self-employed individuals. This is one of the few areas where careful structuring changes the number dramatically.

⚖️ The PFIC Trap: Why Americans Should Not Buy Turkish Funds

US citizens in Turkey should generally avoid Turkish mutual funds, ETFs, and other pooled investment vehicles, because the US PFIC regime taxes them punitively. A Passive Foreign Investment Company, or PFIC, is broadly any foreign corporation where 75% or more of gross income is passive, or 50% or more of assets produce passive income. That definition captures nearly every foreign fund, including Turkish ones.

The tax treatment is among the harshest in the entire US Code. Under the default regime, distributions and gains from a PFIC are treated as if earned rateably across the holding period, taxed at the highest ordinary income rate (currently 37%), and then loaded with an interest charge applied retroactively. The effective combined rate can climb past 50%. What looks like an ordinary 20% gain to a Turkish investor can become a very different number on a US return.

Elections exist, but they are imperfect. A Qualified Electing Fund election allows current inclusion at more favorable rates, yet it requires the fund to provide a specific annual information statement that foreign funds rarely produce. A mark-to-market election removes the interest charge but taxes unrealized gains annually as ordinary income. Neither is a clean escape, and both demand paperwork the fund itself often will not supply.

The practical rule for Americans in Turkey is straightforward: do not hold Turkish or other non-US pooled funds. Hold US-domiciled ETFs and mutual funds, or individual securities directly, and keep foreign exposure through US-based structures. If you already own foreign funds before moving, have a US tax professional review the position first, because some remediation strategies exist but they are time-sensitive and easy to lose by waiting.

⚖️ Exit Tax and the Renunciation Decision

Renouncing US citizenship can end US taxation permanently, but for some Americans it triggers an exit tax that can be the largest single tax event of their life. This is the ultimate decision on the page, and it is exactly the kind of choice where a clear head matters more than a strong feeling. The exit tax, governed by Section 877A, applies only to “covered expatriates,” so the first task is to determine whether you are one.

You are a covered expatriate if any one of three tests is met at renunciation (or at surrender of a long-term green card held for eight years or more). The first is the tax-liability test: an average annual net US income tax over the five preceding years exceeding roughly 201,000 US dollars (the 2025 figure, indexed annually). The second is the net-worth test: a net worth of 2,000,000 dollars or more on the expatriation date. The third is a certification failure: an inability to certify five years of US tax compliance on Form 8854.

For those who are covered, the exit tax deems a sale of all worldwide assets at fair market value on the day before expatriation. The resulting gain, net of an exclusion of approximately 890,000 US dollars (the 2025 figure, indexed annually), is taxed at applicable capital gains rates. Deferred compensation, IRAs, 401(k)s, and interests in trusts each carry their own special treatment layered on top.

Whether renunciation makes sense is a quantitative question dressed as an emotional one. When does renouncing actually pay off? When the ongoing annual US tax you would escape is large relative to the one-time exit tax you would pay, and when your unrealized gains are modest enough to keep that exit cost contained. For someone below all three thresholds with a clean compliance record, the exit tax can be zero. For someone with large unrealized gains, it can run into the hundreds of thousands. The decision requires a full asset-by-asset model before any step is taken, never a snap judgment made in frustration with paperwork.

⚖️ Four Real Profiles of US Citizens in Turkey

The abstract rules become clearer through concrete profiles, each showing how the same framework produces very different outcomes depending on income type and wealth.

The remote software engineer. A Turkish-American dual national employed by a California tech company, earning 180,000 dollars in combined salary and equity, moves to Istanbul on a permanent remote arrangement. Turkey taxes the foreign salary at 0% under the exemption. On the US side, the first 130,000 or so is excluded by the FEIE, the remaining salary is taxed at US rates, and the equity is taxed when it vests. The total US burden lands in the low tens of thousands, well below what the same person paid living in the United States, and Istanbul’s lower cost of living widens the gap further.

The passive-income retiree. A US citizen with no Turkish background and a 3,000,000 dollar portfolio generating around 140,000 dollars a year in dividends and gains retires in Istanbul. Turkey taxes that investment income at 0%. But none of it qualifies for the FEIE (it is not earned income), and the FTC gives nothing because there is no Turkish tax to credit. The full US rates on qualified dividends and long-term gains apply, producing an annual US bill in the twenties to low thirties of thousands. The cost-of-living saving in Istanbul still dwarfs that figure, so Turkey remains attractive, just not tax-free.

The consultant who can walk away cleanly. A US citizen of fifteen years abroad, net worth 1,800,000 dollars, unrealized gains 400,000, average annual US tax of 85,000, wants to move to Turkey and renounce. All three covered-expatriate thresholds are missed, so the exit tax is zero. After renunciation there is 0% Turkish tax under the exemption, no US tax, and no FBAR or Form 8938 ever again. This is the cleanest renunciation case: below every threshold, compliant, with a meaningful ongoing US bill that simply disappears.

The high-net-worth investor. A US citizen with an 8,000,000 dollar net worth, 3,500,000 in unrealized gains, and a 250,000 dollar average annual US tax wants to relocate and eventually renounce. The net-worth test makes this person a covered expatriate. After the exclusion, the taxable gain is around 2,600,000 dollars, and the exit tax at long-term rates runs to roughly 620,000, before deferred-compensation and retirement-account treatment. Set against 250,000 a year in avoided future US tax, the exit cost is recovered in about two and a half years, and over a long horizon in Turkey the net advantage is large. Here renunciation may be strongly beneficial, but only after full modeling of every asset and its timing.

⚖️ Practical Strategies for US Citizens in Turkey

A handful of disciplined moves separate Americans who use Turkey well from those who leave money and peace of mind on the table. None of them is exotic; they are the standard toolkit applied with attention to the US-Turkey overlap.

Lean toward earned income where you can. Up to roughly 130,000 dollars of earned income is US tax-free under the FEIE, on top of Turkey’s zero rate. Structuring work so that income arrives as salary or self-employment earnings, rather than passive returns, captures that band. Passive income gets no such shelter on the US side.

Use Roth accounts deliberately. Qualified Roth IRA distributions are US tax-free, which means they are untaxed on both sides once you are a Turkish resident (Turkey’s exemption on one side, qualified Roth status on the other). Roth conversions during low-income years in Turkey can be a quietly powerful tool.

Never buy foreign funds. The PFIC regime can turn an ordinary gain into a 50%-plus effective rate. Keeping investments in US-domiciled funds or direct securities avoids an entirely self-inflicted problem.

Model self-employment tax before choosing a structure. The 15.3% charge survives the FEIE. Employment through a foreign entity, or coverage under the Turkish social security system via the totalization agreement, can change the outcome materially.

Keep reporting impeccable. File the FBAR every year you cross the 10,000 dollar threshold, and attach Form 8938 whenever its thresholds are met. The cost of compliance is small; the cost of discovery through Turkish bank reporting is not.

Treat renunciation as a modeled option, not a mood. If your ongoing US tax is high and your unrealized gains are manageable, commission a renunciation analysis, and do it before moving, while asset values and rates are known.

❓ Frequently Asked Questions

✅ Will moving to Turkey mean I stop paying US taxes?

No. Unless you renounce US citizenship or surrender a long-term green card, US worldwide taxation continues regardless of where you live. Turkey’s 20-year exemption removes Turkish tax on foreign income, but it does not remove US tax on anything.

✅ How does the IRS know about my Turkish bank account?

The IRS learns about it automatically, without you saying a word. Turkey is a FATCA partner jurisdiction, so Turkish banks identify their US-person account holders and report the account details to Turkish authorities, who then share that information with the IRS. By the time you file, the IRS can already match your return against what your Turkish bank reported.

✅ Is there any way to avoid the FBAR while living in Turkey?

No. If your foreign accounts exceed 10,000 US dollars at any point in the year, the FBAR is legally required, and there is no expat exemption. It is a simple online form, and non-filing carries severe potential penalties, so the practical answer is always to file it.

✅ Do I need to report a Turkish account under 10,000 dollars, and what changes above 100,000?

The 10,000 dollar FBAR threshold is an aggregate across all your foreign accounts, not a per-account figure. If the combined highest balance of every foreign account you hold stays under 10,000 dollars for the whole year, no FBAR is due. At 100,000 dollars you are well above the FBAR threshold and must file the FBAR, though a balance at that level is usually still below the higher Form 8938 thresholds that apply to Americans living abroad (200,000 dollars at year-end or 300,000 at any time for single filers).

✅ Can I just not tell the IRS I moved to Turkey?

No. Turkish banks report US-citizen accounts to Turkish authorities, who share the data with the IRS under FATCA. Attempting to hide Turkish residency or accounts is tax evasion, a criminal matter, not a planning strategy.

✅ What is the penalty if I never disclosed my Turkish account or income?

It depends on whether the failure was non-willful or willful. A non-willful FBAR violation can draw a penalty of up to 10,000 US dollars, while a willful violation can reach the greater of 100,000 dollars or half the account balance, with potential criminal exposure. The important point is that the IRS offers streamlined and voluntary disclosure procedures for taxpayers who come forward before being contacted, and these often reduce or eliminate penalties, which is why acting early with proper advice matters so much.

✅ Do I owe both Turkish and US income tax if I live in Turkey?

On foreign-source income, Turkey taxes at 0% under the exemption while the US taxes at standard rates, and the Foreign Tax Credit does not help because there is no Turkish tax to credit. On Turkish-source income, Turkey taxes at standard rates and the US also taxes, but the credit on the Turkish portion reduces the US bill.

✅ Does Turkey’s 20-year exemption make me tax-free as an American?

Only on earned income within the FEIE band. For salary up to roughly 130,000 dollars the combination of Turkey’s exemption and the FEIE produces genuine zero tax, but investment income, pensions, and earned income above the band remain subject to US tax.

✅ Should I renounce my US citizenship to benefit from Turkey’s exemption?

It depends on your net worth, annual US tax, and unrealized gains. For those below the covered-expatriate thresholds it can be clean and highly advantageous, while for those with large unrealized gains the exit tax may make it counterproductive, so a full model is essential before deciding.

✅ My spouse is not a US citizen. Does that affect my FBAR or FATCA obligations?

Your FBAR covers accounts you own or control, including joint accounts with a non-citizen spouse. For US income tax and Form 8938, a non-citizen spouse’s income generally does not affect your return unless you choose to file jointly, which creates its own complications.

✅ Why is the exemption worth so much less to me than to a German or Turkish neighbor?

Because the US taxes citizens on worldwide income while Germany and Turkey tax based on residence. When Turkey’s exemption sets the local tax to zero, your German or Turkish neighbor owes nothing anywhere, while you still owe the US in full on most income.

⚖️ US Citizens Can Benefit From Turkey, With Eyes Open

Turkey’s 20-year exemption is worth materially less to a US citizen than to almost anyone else, and that is not a reason to dismiss Turkey. It is a reason to plan with both tax systems in view rather than one. The Americans who struggle are the ones who let a comforting first impression, no Turkish tax, stand in for the whole truth. The ones who thrive accept the US layer early and build around it.

The genuine benefits are real. Up to roughly 130,000 dollars of earned income is zero-taxed on both sides, Turkey’s cost of living remains a substantial and durable advantage, Roth distributions escape tax entirely, dual nationals keep both passports until they choose otherwise, and for the right profile renunciation eventually removes the US layer altogether. Against those benefits sit the obligations that never sleep: annual FBAR and Form 8938 filing, Self-Employment Tax that the FEIE does not reach, no Foreign Tax Credit on passive income, the PFIC trap on foreign funds, and the exit tax for those who consider leaving US citizenship behind.

The question this page opened with was whether moving to Turkey ends US taxes. It does not, and knowing that clearly is itself the first planning decision. Everything that follows, from which accounts to hold to whether to renounce, is easier once the two systems are seen for what they are: one that switches off at the Turkish border, and one that follows the passport home.