Acquiring Turkish Citizenship by Investment

2 June 2021 Cetin Attorney Partnership

Turkish law allows foreign nationals who make a qualifying investment to acquire Turkish citizenship on an exceptional basis by Presidential decision. The legal basis is Article 12 of the Turkish Citizenship Law No. 5901, and the investment criteria are set out in Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law. In every case, the applicant must not pose a threat to national security or public order.

Legal Framework

Article 12 of Law No. 5901 lists the cases in which Turkish citizenship may be acquired exceptionally, such as bringing industrial facilities to Türkiye or rendering extraordinary services in scientific, technological, economic, social, sporting, cultural or artistic fields. Acquisition through investment falls under Article 12(1)(b). Article 20(2) of the Regulation specifies the qualifying investments, and a foreign national who meets any one of them may apply.

Qualifying Investments

Each criterion is verified by a designated public authority.

  1. A fixed capital investment of at least USD 500,000 or its equivalent in foreign currency, verified by the Ministry of Industry and Technology.
  2. The purchase of real estate worth at least USD 400,000 or its equivalent in foreign currency, with an annotation in the land registry that the property will not be sold for three years. The property must be subject to condominium ownership or a construction servitude, or must be land on which a building stands. A notarised promise to sell agreement also qualifies where at least USD 400,000 has been paid in advance and an undertaking not to transfer the property for three years is annotated in the land registry. This criterion is verified by the Ministry of Environment, Urbanisation and Climate Change.
  3. The creation of employment for at least 50 persons, verified by the Ministry of Labour and Social Security.
  4. A deposit of at least USD 500,000 or its equivalent in foreign currency with banks operating in Türkiye, held for three years, verified by the Banking Regulation and Supervision Agency.
  5. The purchase of government debt instruments worth at least USD 500,000 or its equivalent in foreign currency, held for three years, verified by the Ministry of Treasury and Finance.
  6. The purchase of real estate investment fund or venture capital investment fund participation shares worth at least USD 500,000 or its equivalent in foreign currency, held for at least three years, verified by the Capital Markets Board.
  7. A contribution of at least USD 500,000 or its equivalent in foreign currency to the private pension system, held in funds designated by the Insurance and Private Pension Regulation and Supervision Agency and kept in the system for three years, verified by that Agency.

Currency Conversion and Valuation

For the real estate, deposit, government debt, fund share and private pension routes, the foreign currency must be sold before the transaction to a bank operating in Türkiye, which in turn sells it to the Central Bank of the Republic of Türkiye. The Turkish lira obtained for the deposit, government debt and private pension routes is then held for three years in Turkish lira deposits, Turkish lira government debt instruments or the designated pension funds respectively. Investment amounts are valued at the Central Bank’s effective selling rate or cross rate on the date of determination.

Moving Between Investment Types

Where the required holding period has not yet been completed, the investor may move between the qualifying investment types in order to complete it. Each authority determines its own procedures for verifying whether the conditions are met.

Application Procedure

Once the relevant authority confirms that the investment criterion is met, the application authorities prepare the citizenship file upon the written instruction of the Ministry of Interior. The file includes the application form, a passport or similar document showing nationality, documents on marital status, a birth certificate or civil registry record with documents proving family ties with the spouse and children, civil registry records of any first or second degree Turkish relatives, a document completing the date of birth where the day and month are missing, and the receipt for the service fee. The completed file is sent to the Ministry of Interior and the decision is taken by the President.

Conclusion

Citizenship by investment offers a defined route to Turkish citizenship, but each criterion carries technical conditions such as holding periods, land registry annotations and mandatory currency conversion. A failure to meet any of these conditions may delay or prevent the application, so the structure of the investment should be reviewed before funds are transferred. For further information on the process, you may contact us at info@cetinavukatlik.com.

AV. ALPER ÇETİN (alper@cetinavukatlik.com)

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