Turkish Citizenship by Investment: Routes and Amounts

Turkish citizenship by investment rests on the exceptional acquisition route in Article 12 of Law No. 5901 (5901 sayılı Türk Vatandaşlığı Kanunu m.12), and its concrete conditions are listed in Article 20(2) of the implementing Regulation (Türk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik m.20). Those Turkish titles are given here because the official texts are published under them. That paragraph sets out seven separate routes: a fixed capital investment of at least USD 500,000, real estate of at least USD 400,000 with a three-year no-sale annotation, employment of at least fifty people, a bank deposit of USD 500,000 held for three years, government debt instruments in the same amount, investment fund participation shares, and a private pension contribution. Each subparagraph has its own amount, its own holding period and its own determining authority.

The amount is converted at the Central Bank rate on the date of determination rather than the date of the transaction (Article 20(6) of the implementing Regulation), and on five of the routes the foreign currency is sold to a Turkish bank and by that bank to the Central Bank before the transaction (Article 20(10)). Because these figures are set by secondary legislation they change; the current amount should be verified at the time of application. Meeting the condition does not guarantee the outcome (Article 10 of Law No. 5901). Citizenship once acquired may be annulled where there was a false declaration (Article 31) or withdrawn where the legal conditions were not met (Article 40). The Turkish-language treatment of the same subject is at yatırımla Türk vatandaşlığı.

1. Turkish Citizenship by Investment: Minimum Amounts and the Seven Routes

For Turkish citizenship by investment, Article 20(2) of the implementing Regulation frames the routes as alternatives: a foreign national who satisfies any one of the listed conditions may acquire Turkish citizenship by Presidential decree within the scope of Article 12(1)(b) of Law No. 5901. Satisfying one route is enough; there is no requirement to combine them.

Subparagraph	Investment	Amount	Holding period	Determining authority
a	Fixed capital investment	USD 500,000	(none stated)	Ministry of Industry and Technology
b	Real estate	USD 400,000	3 years	Ministry of Environment, Urbanisation and Climate Change
c	Employment	(no monetary threshold)	(none stated)	Ministry of Labour and Social Security
ç	Bank deposit	USD 500,000	3 years	Banking Regulation and Supervision Agency
d	Government debt instruments	USD 500,000	3 years	Ministry of Treasury and Finance
e	Investment fund participation shares	USD 500,000	at least 3 years	Capital Markets Board
f	Private pension contribution	USD 500,000	3 years in the system	Insurance and Private Pension Regulation and Supervision Agency

Three distinctions in this table change the outcome of any comparison. First, the employment route carries no monetary threshold; the test is the number of people employed, not a sum invested. Second, real estate stands alone at USD 400,000, while the other five monetary routes require USD 500,000, so the lowest entry threshold is on the property route. Third, the determining authority changes with the route. Comparing the routes by threshold alone is therefore incomplete: behind the same figure sit a different institution, a different evidential file and a different formulation of the holding period.

2. Turkish Citizenship by Investment in Real Estate: USD 400,000 and a Three-Year Annotation

The property route to Turkish citizenship by investment requires real estate worth at least USD 400,000, or the equivalent in foreign currency, to be purchased with a three-year no-sale annotation entered on the title deed records, as determined by the Ministry of Environment, Urbanisation and Climate Change (Article 20(2)(b) of the implementing Regulation). The subparagraph was last amended by Presidential Decision No. 5554 of 13 May 2022.

Two elements are required together and one does not substitute for the other: the value threshold and the title deed annotation. A purchase that meets the amount but carries no annotation does not complete the property route.

The character of the property is also restricted. The subparagraph requires property with condominium ownership or a condominium right established over it, or land with a building on it. That restriction was introduced by Presidential Decision No. 7938 of 12 December 2023; before it, the subparagraph referred simply to “property”. The binding consequence today is that bare land with no condominium ownership, no condominium right and no building on it is not sufficient on its own, however far it exceeds the threshold. The separate rules on who may buy property in Turkey and where are covered in property acquisition by foreigners.

2.1. Turkish Citizenship by Investment Through a Notarised Promise to Sell

For Turkish citizenship by investment in property, the same subparagraph offers a second route alongside outright purchase. Here, for property over which condominium ownership or a condominium right has been established, at least USD 400,000 or the equivalent is paid in advance, an undertaking that no transfer or cancellation will be made for three years is annotated on the land registry, and the sale is promised through a contract drawn up before a notary (Article 20(2)(b) of the implementing Regulation).

The difference between the two options lies in what the annotation records. On the first, the annotation is a no-sale annotation; on the second it is an undertaking that no transfer or cancellation will be made for three years. The three-year retention element is common to both; what changes is where ownership sits during that period. Note also that the second option is limited in the text to property with condominium ownership or a condominium right; it does not mention land with a building on it.

3. Turkish Citizenship by Investment in a Bank Deposit: USD 500,000 Held for Three Years

The deposit route to Turkish citizenship by investment requires a deposit of at least USD 500,000, or the equivalent in foreign currency, to be placed with banks operating in Turkey on condition that it is held for three years, as determined by the Banking Regulation and Supervision Agency (Article 20(2)(ç) of the implementing Regulation).

Three elements are required together: the amount, the three-year period, and placement with a bank operating in Turkey. The same sum held in an account abroad does not satisfy this subparagraph.

This route appears to be the simplest of the seven because it involves no property selection and no valuation. The simplicity is misleading on one point. Under the conversion rule discussed below, what is held for three years is not the dollars but the Turkish lira obtained by selling them to the Central Bank (Article 20(10)). An investor on the deposit route meets the threshold in dollars but spends the three-year period in Turkish lira, and therefore carries the currency risk personally.

4. Turkish Citizenship by Investment in Government Bonds and Fund Shares

Turkish citizenship by investment has two separate subparagraphs on the capital markets side. Their amounts are identical and their determining authorities are not.

The government debt instrument route requires instruments worth at least USD 500,000, or the equivalent, to be purchased on condition that they are held for three years, as determined by the Ministry of Treasury and Finance (Article 20(2)(d) of the implementing Regulation). The subparagraph uses “purchased” and “on condition that they are held for three years” together: acquisition alone is not enough, the instruments must be retained through the period.

The investment fund route covers real estate investment fund participation shares or venture capital investment fund participation shares worth at least USD 500,000, purchased on condition that they are held for at least three years, as determined by the Capital Markets Board (Article 20(2)(e) of the implementing Regulation). This subparagraph covers two distinct fund types, and its wording is “held for at least three years”.

5. Turkish Citizenship by Investment in a Private Pension: USD 500,000 and Three Years

The private pension route is the newest of the seven Turkish citizenship by investment routes, added by Presidential Decision No. 5554 of 13 May 2022. It requires a contribution of at least USD 500,000, or the equivalent, to be paid into the private pension system, held in funds whose scope is determined by the Insurance and Private Pension Regulation and Supervision Agency, with three years spent in the system, as determined by that same Agency (Article 20(2)(f) of the implementing Regulation).

Two separate conditions stack here, and neither is left to the investor’s free choice. The contribution must sit in funds whose scope the Agency sets, not in any pension fund, and the period in the system is three years. If the fund is chosen wrongly, the subparagraph is not satisfied even where the amount is met.

6. Turkish Citizenship by Investment in Fixed Capital: USD 500,000

The first Turkish citizenship by investment subparagraph requires a fixed capital investment of at least USD 500,000, or the equivalent, to have been made, as determined by the Ministry of Industry and Technology (Article 20(2)(a) of the implementing Regulation).

This route differs from the property route in two respects. The threshold is USD 500,000, and the subparagraph states no separate holding period. The absence of a stated period does not mean the investment can be made and unwound; the test is that the Ministry determines the investment to have been made, and the determination procedure is set by the authority itself (Article 20(9)). On company formation in Turkey see setting up a company in Turkey as a foreigner.

7. Turkish Citizenship by Investment in Jobs: Employing at Least Fifty People

The employment route is the only Turkish citizenship by investment subparagraph with no monetary threshold. It requires the creation of employment for at least fifty people, as determined by the Ministry of Labour and Social Security (Article 20(2)(c) of the implementing Regulation).

The test is the employment created, not a sum invested. The route concerns foreign nationals who already run, or will establish, a business in Turkey, because its test is the number of jobs rather than a sum locked into one transaction. On the incentives attached to particular locations see investment zones: free zones, technoparks and OSB.

8. Turkey Citizenship by Investment: the Currency Is Sold to the Central Bank First

Five of the seven Turkish citizenship by investment routes require the currency to be sold before the transaction. The foreign currency amounts under the property, deposit, government debt instrument, investment fund and private pension subparagraphs are sold before the transaction to a bank operating in Turkey, and by that bank to the Central Bank (Article 20(10) of the implementing Regulation). The Turkish lira proceeds are then held for three years: deposit proceeds in a Turkish lira deposit, government debt instrument proceeds in Turkish lira denominated instruments, and private pension proceeds in the funds determined by the relevant Agency.

Two consequences follow. First, the sale is made before the transaction. Completing the investment and converting the currency afterwards does not satisfy the condition, and the sequence cannot be repaired retrospectively. Second, on the deposit, government debt instrument and private pension routes what is held for three years is Turkish lira, not dollars, so the investor carries the currency risk through that period. On the property and investment fund routes what is retained is the asset itself rather than converted cash. Comparing the routes by threshold alone is incomplete for this reason: the same USD 500,000 carries a different risk depending on the subparagraph chosen.

9. Turkish Citizenship by Investment and the Exchange Rate: Date of Determination, Not of Transaction

All the Turkish citizenship by investment thresholds are expressed in dollars while the transaction takes place in Turkey. The Regulation states which moment governs the conversion: monetary values are established using the Central Bank of the Republic of Türkiye effective selling rate and/or cross exchange rate on the date of determination (Article 20(6) of the implementing Regulation).

The governing date is the date of determination, not the date of the transaction. The distinction has practical consequences. If the rate moves between purchase and determination, an amount that comfortably cleared the threshold at the moment of the transaction can fall below it at the moment of determination.

The practical conclusion is that transacting at an amount very close to the threshold is itself a risk. Keeping the amount somewhat above the threshold is not a legal requirement, but it is a precaution that can be sized against the expected exchange rate movement between the two dates.

10. Turkish Citizenship by Investment: Can You Change the Investment Type?

In Turkish citizenship by investment, changing route before the period expires does not restart the clock. Movement between the investment types under paragraph two is possible for the purpose of completing the stated period (Article 20(8) of the implementing Regulation).

The operative words are “for the purpose of completing the stated period”. A year spent in a deposit is not erased when the investor moves to government debt instruments; it counts towards completion of the three years. The procedure for the change is set by the authority making the determination (Article 20(9)), so the switch is not a free choice but an operation carried out within that authority’s own rules. The procedure should be confirmed with the target route’s determining authority before the type is changed.

11. Turkish Citizenship by Investment Thresholds: How They Have Changed

The Turkish citizenship by investment conditions have been amended by six instruments since 2016, so a plan built on an old figure still circulating online can fall below the threshold. The official footnotes to Article 20 of the implementing Regulation record the amendments with their dates:

Date	Instrument	What changed
12.12.2016	Council of Ministers Decision 2016/9601	Paragraph two, listing the investment routes, was added; the conversion rule in paragraph six came with the same Decision
13.03.2017	Decision 2017/10008	The investment fund participation share subparagraph (e) was added
19.09.2018	Presidential Decision No. 106	The deciding authority moved from “the proposal of the Ministry and the Council of Ministers” to the President; “and/or cross exchange rate” was added to the conversion rule; paragraph eight on switching was added
06.01.2022	Presidential Decision No. 5072	Subparagraphs a, b, c, ç, d and e were all amended; paragraph nine and paragraph ten, requiring sale of the currency to a bank and to the Central Bank, were added
13.05.2022	Presidential Decision No. 5554	The property threshold was raised from USD 250,000 to USD 400,000; the private pension subparagraph (f) was added
12.12.2023	Presidential Decision No. 7938	The definition of qualifying property was narrowed: the plain word “property” became “property with condominium ownership or a condominium right established over it, or land with a building on it”

Two conclusions follow. First, the routes and thresholds were amended by six instruments in seven years, so no figure in this area can be treated as permanent. Second, the 2023 amendment was a change of character rather than of amount, and it can place outside the scope a property that exceeds the threshold comfortably. Checking the amount does not substitute for checking the character.

The USD 250,000 figure still found in older sources predates the fifth row of this table. The threshold in force since 13 May 2022 is USD 400,000, and any plan built on the older figure falls below the threshold at the determination stage. The last amendment recorded in the official footnotes to Article 20 is the 2023 Decision, which changed the character of qualifying property rather than the amount.

12. Turkish Citizenship by Investment: Documents Required for the Application

In Turkish citizenship by investment, determination of the investment and the citizenship file are separate matters. The file is compiled by the application authorities upon the written instruction of the Ministry, and once complete it is sent to the Ministry for a decision (Article 20(3) and Article 20(4) of the implementing Regulation). Where considered necessary, applications under Article 12(1)(b) may be taken by the Ministry itself (Article 20(5)).

The Regulation groups the documents as follows: a form petition stating the request; a passport or equivalent document showing which state the person is a national of, and where the person is stateless a document to that effect if one can be obtained; a civil status document together with the marriage certificate if married, the divorce certificate if divorced, or the spouse’s death certificate if widowed; a birth certificate or population register extract showing identity details, and where married the record establishing the family link of the spouse and children; where applicable a population register extract for first or second degree relatives who are Turkish citizens; where the day and month of birth are missing, the document completing them or a signed declaration accepting treatment under Article 39 of Law No. 5490; and the receipt showing that the service fee has been paid.

The point to note is that all of these documents concern the person and the family. The documents proving the investment itself do not belong to this file; they are assessed at the determination stage carried out by the relevant authority. Treating the two stages as a single file leads to a citizenship application being made before the investment has been determined, and to the file being returned as incomplete.

13. Turkish Citizenship by Investment: How to Apply, and the Investor Residence Permit

The Turkish citizenship by investment process begins with the choice of investment and ends with a Presidential decree; the diagram below the article sets out the order. Along the way the investor and family receive a short-term residence permit, available to those who will make an investment of the scope and amount to be determined by the President without working in Turkey, and to their foreign spouse and their own and their spouse’s minor or dependent foreign children (Article 31(1)(j) of Law No. 6458, published as 6458 sayılı Yabancılar ve Uluslararası Koruma Kanunu m.31).

The duration rules for this permit sit in two paragraphs that must be read together. The general rule that short-term residence permits may be issued for periods of up to two years at a time is framed excluding subparagraphs (j) and (k) (Article 31(2) of Law No. 6458). The fifth paragraph then provides that permits issued under those subparagraphs may be granted for periods of up to five years (Article 31(5)).

Reading one of these paragraphs without the other reverses the conclusion. The investor permit is exempt from the two-year ceiling, but it is not without a ceiling; its own ceiling is five years. An exemption from the general rule is not an unlimited permit. A sixth paragraph added by Law No. 7533 of 21 November 2024 further provides that the character and value of the property on which a short-term residence permit is based are determined by the Ministry (Article 31(6)), so the property test on the residence permit side is subject to an administrative determination separate from the Article 20 test on the citizenship side. For the distinction from other permits, see residence permit types in Turkey.

Where the permit is refused or cancelled, a specific procedure applies to the resulting court action. In applications made to the court by the foreign national, their legal representative or their lawyer, the file is deemed complete once the defence is submitted or the time for submitting it has expired; where notification cannot be made to the address given by the claimant, the period in Article 26(3) of Law No. 2577 applies as two months; and whether a hearing is held is at the court’s discretion (Article 31(7) of Law No. 6458, added by Law No. 7533 of 21 November 2024). The residence permit limb of an investor’s case therefore runs on a tighter timetable than general administrative procedure.

Because the process involves several ministries, the Regulation provides for a coordination structure: a commission composed of representatives of the Ministry of Labour and Social Security, the Ministry of Environment, Urbanisation and Climate Change, the Ministry of Treasury and Finance and the Ministry of Industry and Technology may be established within the Ministry of the Interior to follow the process (Article 20(7) of the implementing Regulation). The paragraph does not make establishment compulsory, so this is an internal coordination facility for the administration rather than a procedural guarantee for the applicant.

14. Turkish Citizenship by Investment: How Long Does It Take?

Neither Law No. 5901 nor Article 20 of the implementing Regulation prescribes a fixed period within which a Turkish citizenship by investment application must be concluded. The three-year periods in Article 20 concern retaining the qualifying investment or the annotation; they are not processing times, and they should not be presented either as a three-year wait before applying or as a promise that the procedure will finish on a particular date. On timing, the Regulation says only that the completed file is sent to the Ministry for a decision (Article 20(4)).

Any duration quoted for this process is therefore an expectation drawn from practice, not a statutory entitlement. When asking about progress, the useful question is which stage the file has reached: determination of the investment, the residence permit, compilation of the citizenship documents, or consideration by the Ministry. An estimate for one stage does not establish a completion date for the whole application, the national security and public order assessment under Article 12 of Law No. 5901 remains part of the decision throughout, and the three-year investment commitment continues on its own terms regardless.

15. Turkish Citizenship by Investment and the “Golden Visa” Label

Turkish citizenship by investment is widely marketed under that name, but “golden visa” is a commercial description rather than a term used in Turkish law, and the mismatch matters in two ways. The legal basis is the exceptional acquisition route in Article 12 of Law No. 5901, with the qualifying investments set out in Article 20(2) of the implementing Regulation. The outcome is citizenship granted by Presidential decree, not a visa and not a residence right.

The residence element is a separate instrument: a short-term residence permit issued to the investor under Article 31(1)(j) of Law No. 6458. An applicant who assumes that the “visa” and the citizenship are one process will also assume they are governed by one set of conditions and one timetable, which they are not.

15.1. Turkish Citizenship by Investment and the Turkish Passport

Turkish citizenship by investment is what a “Turkish passport by investment” actually refers to, because the passport is not a separate product of the investment. The ordinary passport is issued to Turkish citizens, within Türkiye by the Ministry of the Interior or the governorships and abroad by Turkish consulates (5682 sayılı Pasaport Kanunu m.15). The citizenship decision takes effect from its date (5901 sayılı Türk Vatandaşlığı Kanunu m.20/1), and the passport is applied for after it, at the places and with the documents set by the Ministry of the Interior (5682 sayılı Pasaport Kanunu m.17). Validity, children’s entries and the cases in which a passport is refused are set out in the guide on how to get Turkish citizenship.

16. Turkish Citizenship by Investment and the VAT Exemption: A Separate Three-Year Rule

A foreign national on the property route to Turkish citizenship by investment may also benefit from a separate tax exemption with a three-year period of its own, distinct from the citizenship annotation. The exemption is in the Value Added Tax Law rather than in the citizenship legislation: deliveries of residences or workplaces made to foreign nationals not resident in Turkey are exempt, provided the delivery is the first delivery of a building constructed as a residence or workplace and the price is brought into Turkey in foreign currency (Article 13(i) of Law No. 3065).

The exemption carries its own sanction in the same subparagraph: where a residence or workplace received under the exemption is disposed of within three years, the tax not collected at the time must be paid, together with deferral interest calculated under Article 48 of Law No. 6183, before the title deed transaction, by the person disposing of it (Article 13(i) of Law No. 3065). The subparagraph also makes the buyer jointly and severally liable with the taxpayer for the tax, the tax loss penalty and the late payment interest where the exemption was applied although its conditions were not met.

The two periods differ on every axis. Their sources differ: one arises from the Regulation, the other from the Law. Their subjects differ: the annotation is an element of the citizenship condition, while the exemption period concerns collection of tax. Their consequences differ: breaching the annotation undermines the citizenship condition, while breaching the exemption period triggers payment of the tax with deferral interest before the title deed transaction. They run alongside each other, but the ending of one does not end the other. For the wider tax picture see taxation of foreign companies in Turkey.

17. Turkish Citizenship by Investment for a Spouse and Children

Turkish citizenship by investment does not extend to the family automatically. Acquisition of Turkish citizenship by decision of the competent authority does not affect the spouse’s citizenship; children under the custody of the mother or father acquire Turkish citizenship where the other spouse consents. Where consent is not given, the matter proceeds according to the decision of the court in the country of the parent’s habitual residence, and children of a mother and father who acquire Turkish citizenship together also acquire it (Article 20(2) of Law No. 5901).

For the spouse, not being affected automatically does not mean being outside the route. Article 12(1)(b) of Law No. 5901 lists, among those who may acquire citizenship through the exceptional route, holders of a residence permit under Article 31(1)(j) of Law No. 6458 together with their foreign spouse and their own and their spouse’s minor or dependent foreign children. The spouse therefore becomes a citizen by a decision concerning the spouse, not as a consequence of the investor’s decision. For children, the Regulation treats joint processing of the child with the mother or father as the rule (Article 37(8) of the implementing Regulation). Where children not processed together with the parent apply after reaching majority, Article 11 of Law No. 5901, the general acquisition route, applies to them (Article 20(3) of Law No. 5901). For that reason the stage at which family members are included should be settled at the outset of the application plan. The separate route based on marriage to a Turkish citizen is covered in Turkish citizenship by marriage.

18. Turkish Citizenship by Investment and Dual Citizenship: Can You Keep Another Nationality?

Turkish citizenship by investment does not require giving up another nationality under Turkish law, which recognises multiple citizenship. Where persons who acquire the citizenship of a foreign state for any reason present the documents relating to that status, and an examination establishes that they are the same persons in the records, an annotation recording that they hold multiple citizenship is entered in their family population registers (Article 44 of Law No. 5901).

This provision governs the Turkish record. It does not determine what effect acquiring Turkish citizenship has under another country’s law, and some states withdraw their nationality on the acquisition of a further one. An applicant wishing to retain an existing nationality must check that country’s own rules separately; the Turkish position alone does not answer the question. The different acquisition routes are compared in the broader Turkish citizenship guide.

19. Turkish Citizenship by Investment for Investors Based in the Gulf: What Turkish Law Governs

Turkish citizenship by investment does not distinguish between investors by country of residence: Article 20(2) of the implementing Regulation addresses “the foreign national” without qualification. Three questions that investors living in the UAE, Saudi Arabia, Qatar or Kuwait raise are nonetheless answered by specific Turkish provisions, and a fourth is not answered by Turkish law at all.

• The right to own property depends on nationality: foreign natural persons may acquire property in Turkey if they are nationals of the countries determined by the President, subject to the statutory limits (Article 35 of Law No. 2644). The test is the investor’s nationality, not the country of residence; a Dubai resident holding another country’s passport is assessed on that nationality. Details are in property acquisition by foreigners.
• Documents issued abroad: the citizenship file requires a passport showing which state the person is a national of, together with civil status and birth documents, and where the date of birth lacks the day and month, a document from the competent authorities of the person’s own country completing it (Article 20(3)(e) of the implementing Regulation). Preparing them starts before the investment is determined, not after.
• VAT exemption: the exemption requires the buyer to be a foreign national not resident in Turkey and the price to be brought into Turkey in foreign currency (Article 13(i) of Law No. 3065), so a transfer from an account abroad bears directly on that condition.
• Keeping the original nationality: Turkish law records multiple citizenship (Article 44 of Law No. 5901), but the effect of Turkish citizenship on the investor’s original nationality is governed by the law of that state, and this article does not answer it.

20. Turkish Citizenship by Investment: Annulment (Article 31) and Withdrawal (Article 40)

Turkish citizenship by investment is not an untouchable status. The Law provides two separate mechanisms for setting aside the acquisition decision, each with its own cause and effect.

Annulment addresses a defect originating in the person’s declaration. Where the decision to acquire Turkish citizenship resulted from the person’s false declaration or from concealment of material matters essential to acquisition, it is annulled by the authority that issued the decision (Article 31 of Law No. 5901). In an investment file this can extend to statements about valuation, the source of funds or identity details.

Withdrawal addresses a defect in the decision itself. Decisions on the acquisition or loss of Turkish citizenship are withdrawn where it is subsequently established that they were issued without the legal conditions being met, or issued more than once (Article 40 of Law No. 5901).

The distinction runs along four axes. By cause, Article 31 rests on a defect in the declaration and Article 40 on a defect in the decision. By timing, Article 31 looks to the declaration made at application, Article 40 to whether the legal conditions existed when the decision was taken. By author, the defect under Article 31 arises from the person’s own conduct, while the text of Article 40 ties withdrawal not to the person’s conduct but to the absence of the conditions or the duplication of the decision. By nature of the act, both are administrative acts and an action for annulment may be brought against either. Collapsing them into a single “loss of citizenship” heading leads to the wrong legal ground being pleaded.

21. Turkish Citizenship by Investment: Challenging Annulment or Withdrawal (Deadline, Court, Stay of Execution)

Annulment and withdrawal of Turkish citizenship by investment are administrative acts, and an action for annulment lies against them. Three procedural points are decisive in practice.

Deadline. Because no separate period is set in the applicable statute, the general period applies: the time for bringing an action is sixty days before the Council of State and the administrative courts, and thirty days before the tax courts (Article 7(1) of Law No. 2577). In administrative disputes the period runs from the day following written notification (Article 7(2)(a)).

Competent court. Unless a statute designates another court, the administrative court for the place where the authority that issued the act is located has jurisdiction (Article 32 of Law No. 2577). Where the act is a Presidential decision, by contrast, the Council of State hears actions for annulment against Presidential decisions as a court of first instance (Article 24(1)(a) of Law No. 2575 on the Council of State). Identifying which authority issued the annulment or withdrawal therefore comes before identifying the court.

Stay of execution. Bringing an action does not suspend the act. A stay requires both conditions to be met together: that implementation of the administrative act would cause damage that is difficult or impossible to remedy, and that the act is manifestly unlawful. The decision is given with reasons after the defendant administration’s defence has been received or the time for it has expired (Article 27(2) of Law No. 2577). One condition alone is not enough; both must be set out separately in the application. A second request for a stay may not be made on the same grounds (Article 27(10)).

22. Turkish Citizenship by Investment: What Happens to the Property If Citizenship Is Withdrawn?

A person whose withdrawal decision on Turkish citizenship by investment becomes final returns to foreign status. From that point the property they hold falls under the general regime governing acquisition of property by foreign nationals. The total area of property and independent and permanent limited rights in rem acquired by foreign natural persons may not exceed ten per cent of the district area subject to private ownership, nor thirty hectares per person nationwide (Article 35 of Law No. 2644).

The same article provides a liquidation procedure: property and limited rights in rem acquired contrary to the article, found by the relevant Ministry and administrations to be used contrary to the purpose of acquisition, where no application was made to the relevant Ministry in time or projects were not realised in time, together with those acquired by inheritance outside the limits in the first paragraph, are liquidated and converted into money if not liquidated by the owner within a period of up to one year set by the Ministry of Finance, and the price is paid to the rightholder (Article 35 of Law No. 2644).

Two honest limits should be drawn on how this provision reads. First, withdrawal of citizenship is not listed among the grounds for liquidation in the text of the article. The liquidation regime depends on the property having been acquired contrary to the article, or on one of the other listed situations arising. The sentence “if citizenship is withdrawn the property is automatically sold” is not what the article says. What produces the consequence in practice is that the person returns to foreign status, the country, area and surface limits begin to apply to them, and those limits are then found to be exceeded.

Second, liquidation is not confiscation. If the owner does not sell within the period, the property is liquidated, converted into money, and the price is paid to the rightholder. What the owner loses is ownership itself and the ability to choose the timing of the sale, not the value. The country list, the ten per cent district limit and the thirty hectare cap are set out in detail in property acquisition by foreigners.

Related reading: How to acquire Turkish citizenship · Turkish citizenship by marriage · Property acquisition by foreigners · Residence permit types in Turkey · Yatırımla Türk vatandaşlığı (Türkçe)