Tax Residency and the Taxation of Foreigners in Türkiye

Whether Türkiye can tax your worldwide income or only your Türkiye-source income depends on one question: are you a tax resident here? Under the Income Tax Law (Gelir Vergisi Kanunu No. 193), a "full taxpayer" (tam mükellef) is taxed on income earned anywhere in the world, while a "limited taxpayer" (dar mükellef) is taxed only on income arising in Türkiye. This guide explains how that residency line is drawn, what each status means for your tax bill, the special carve-out for people who come for a defined assignment, and how a double tax treaty can change the result.

Resident vs non-resident: the two taxpayer categories

Turkish income tax law sorts every individual into one of two categories, and that single choice drives almost everything else. The rules sit in the Income Tax Law (Gelir Vergisi Kanunu No. 193).

A full taxpayer (tam mükellef, literally "full obligee") is someone Türkiye treats as a tax resident. A full taxpayer is liable to Turkish income tax on income earned anywhere in the world — salary from abroad, rental income on a property in another country, foreign dividends, and so on, in principle all fall within the Turkish net.

A limited taxpayer (dar mükellef, "narrow obligee") is a non-resident. A limited taxpayer is liable only on income that arises in Türkiye — for example, rent from a Turkish apartment, a salary for work physically performed here, or gains from a Turkish business. Income earned outside Türkiye stays outside the Turkish tax base.

This is why the residency question is not a formality. The same person, with the same income, can owe very different amounts depending on which side of the line they fall.

How Türkiye decides if you are a resident

Under the Income Tax Law (No. 193), you are treated as a resident (full taxpayer) if you meet either of two alternative tests. You do not need to satisfy both — one is enough.

Test 1: Legal residence in Türkiye (ikametgah)

The first test looks at whether your legal residence (ikametgah — your settled, habitual home) is in Türkiye. This is a substance test, not just a paperwork test: it asks where your actual centre of living is, drawing on the concept of domicile in the Turkish Civil Code. Holding a residence permit, owning or renting a home, and moving your family and life to Türkiye all point toward this.

Test 2: Continuous presence beyond a day threshold

The second test is time-based. If you stay in Türkiye continuously for more than a set number of days within a single calendar year, you are treated as a resident even if your formal home is elsewhere. There is a commonly cited day threshold for this test, but because the exact figure and the way temporary departures are counted are technical points, you should confirm the current threshold and the counting rules before relying on them (see our review flags below).

The law also recognises that short, temporary absences — a holiday, a business trip, a medical visit abroad — do not necessarily "reset" or break the continuity of your stay. How those interruptions are treated is exactly the kind of detail where careful reading of the statute matters.

Meeting either test makes you a full taxpayer for that year.

The special rule for people who come for a defined job or assignment

There is an important carve-out. The Income Tax Law (No. 193) provides that certain people who come to Türkiye for a specific, defined purpose and a limited period are not treated as residents, even if their stay runs past the day threshold.

The classic example is someone sent to Türkiye for a particular job, project, assignment, study, medical treatment, or similar defined task, who is here only for the duration of that task and intends to leave once it is done. The logic is that such a person has not relocated their life to Türkiye; they are here for a finite reason.

This matters a great deal for seconded employees, project staff, and assignees sent by a foreign parent company. Done right, this rule can keep an assignee a limited taxpayer — taxed in Türkiye only on Türkiye-source income — rather than exposing their worldwide income to Turkish tax. But the exclusion is fact-specific: it depends on the genuine nature of the assignment, its time limits, and your overall ties to Türkiye. It is not automatic, and it is easy to lose if your situation drifts toward genuine relocation. This is a point to confirm with counsel for your specific facts.

What each status means for your tax bill

Once your status is settled, the consequences follow.

If you are a full taxpayer (resident):

• You are, in principle, taxable in Türkiye on your worldwide income across the income categories the law recognises (employment income, business income, rental income, investment income, and so on).
• You may have filing obligations in Türkiye for foreign income that is not taxed at source here.
• Where the same income has already been taxed abroad, relief from double taxation may be available — through a treaty or through domestic foreign-tax-credit mechanisms — but it generally must be claimed, with proof, and is subject to limits.

If you are a limited taxpayer (non-resident):

• You are taxable only on Türkiye-source income. Foreign income is outside scope.
• Much of your Türkiye-source income (for example certain payments to non-residents) may be taxed by withholding at source rather than by annual return, which can simplify compliance.
• Some income types and exemptions are treated differently for non-residents than for residents.

Income tax is charged on a progressive rate scale that the tax authority updates, and various thresholds and exemptions are revalued periodically. We have deliberately not stated rates or figures here because they change — confirm the current brackets, rates and exemption amounts against the law in force for the relevant year.

How tax treaties can change the outcome

Domestic Turkish rules are only half the picture. Türkiye has a wide network of double taxation avoidance agreements (tax treaties) with other countries, and where a treaty applies it can override the domestic residency result.

Two treaty features matter most:

• Tie-breaker rules. If both Türkiye and your home country consider you a resident under their own laws, the treaty's tie-breaker tests (typically permanent home, then centre of vital interests, then habitual abode, then nationality) decide which country gets to treat you as resident for treaty purposes. This can pull you out of Turkish worldwide taxation even where domestic law would have caught you.
• Reduced or zero withholding. Treaties commonly cap the tax Türkiye may withhold on cross-border dividends, interest, royalties and certain service fees, often below the domestic rate. Claiming the treaty rate usually requires a certificate of tax residence from your home country and timely documentation.

Because treaty wording differs country by country, the right answer for a German resident, a UK resident, and a Gulf-based investor can each be different. Before you file or restructure, check whether a treaty applies and exactly what it says.

Practical steps for foreigners and foreign investors

If you are arriving in, investing in, or being assigned to Türkiye, a few steps reduce surprises:

• Map your status early. Work out, for each tax year, whether you are likely to be a full or limited taxpayer — ideally before you cross the day threshold, not after.
• Keep a day-count record. Entry and exit dates, and the reasons for any absences, are the evidence you will need if your residency is ever questioned.
• Document the purpose of an assignment. If you are relying on the defined-assignment carve-out, the secondment letter, project scope and time limits are what support it.
• Check for a treaty first. Before assuming a Turkish rate applies, confirm whether a treaty caps it — and gather the residence certificate you will need to claim it.
• Coordinate Türkiye with home-country filing. Relief from double taxation generally has to be claimed correctly in both jurisdictions; the two filings should be planned together.

Corporate investors should also remember that companies are taxed under a separate regime — the Corporate Tax Law (Kurumlar Vergisi Kanunu No. 5520), which draws its own resident/non-resident line for companies — and that VAT (Katma Değer Vergisi Kanunu No. 3065) and procedural rules (Vergi Usul Kanunu No. 213) sit alongside the income tax analysis.

If you disagree with a tax assessment

If the tax office reaches a residency conclusion you disagree with — for example, treating you as a full taxpayer when you believe you qualified for the assignment carve-out — there are routes to challenge it. Procedural and assessment rules sit in the Tax Procedure Law (Vergi Usul Kanunu No. 213), and tax disputes are litigated before the tax courts under the Administrative Procedure Law (İdari Yargılama Usulü Kanunu No. 2577).

These channels run on strict deadlines. The periods for an administrative objection, for any settlement (uzlaşma) route, and for filing suit are short and are calculated from defined trigger dates, so timing is critical — and we have not stated the exact periods here because they should be confirmed against the current law for your situation. If you receive an assessment, treat it as time-sensitive and take advice promptly.

Frequently asked questions