GVK Mükerrer Madde 20/D in English: The Annotated Translation of Turkey’s 20-Year Exemption

Illustration of an official gazette page with a red seal beside an annotated translation page and a fountain pen

Last reviewed: 24 July 2026. This is an unofficial translation for educational purposes — Türkiye publishes no official English versions of its laws, and where anything matters, the Turkish text controls. Not tax or legal advice; see the disclaimer. Update: the this page anticipated — Income Tax General Communiqué No. 333 — published on 4 July 2026; the commentary below has been revised where it answered a question.

When Law No. 7582 was published in the Official Gazette on 4 June 2026, it created the most generous new-resident tax regime in Türkiye's history — and left the entire English-speaking world reading second-hand summaries of a statute none of them could quote. This page fixes that. Below is the operative text: the new of the Income Tax Law, the companion inheritance-tax amendment, and the entry-into-force clause — each paragraph in the original Turkish, followed by our English translation and a note on what the clause actually does. Everything here is quoted from the Gazette text; nothing is paraphrased from law-firm blogs. For the full analysis — eligibility mechanics, worked examples, the open questions — see the definitive Law 7582 guide.

A translator's note before the text: Turkish income tax law thinks in a twin category — kazanç ve iratlar, "earnings and revenues" — covering both active earnings and investment-type income. And "mükerrer madde" (literally "repeated article") is how Turkish statutes insert new articles between existing numbers, the way other systems say "Article 20-bis." Neither term has a perfect English twin; we translate them consistently and flag them where they carry weight.

Article 4 of Law 7582 — the exemption itself

Article 4 inserts the new provision into the Income Tax Law (Law No. 193), after the existing mükerrer madde 20/C. The inserted article's title:

"Yurt dışından elde edilen kazanç ve iratlar için vergi istisnası"

Tax exemption for earnings and revenues derived from abroad

Paragraph 1 — the twenty-year exemption

"MÜKERRER MADDE 20/D- Türkiye'de yerleşmiş sayılan gerçek kişilerin, Türkiye'de yerleşmiş sayılmasından önceki son üç takvim yılında Türkiye'de ikametgahının ve vergi mükellefiyetinin bulunmaması şartıyla Türkiye dışında elde ettiği kazanç ve iratları yirmi yıl boyunca gelir vergisinden müstesnadır."

Translation: The earnings and revenues derived outside Türkiye by natural persons deemed settled in Türkiye are exempt from income tax for twenty years, provided that, in the last three calendar years preceding their being deemed settled in Türkiye, they had neither a nor a tax liability in Türkiye.

What it does: everything hangs on two phrases. "Deemed settled" (yerleşmiş sayılan) is Turkish — acquired by domicile or by more than six months' continuous presence in a calendar year, under Articles 3–5 of the same law. And the lookback is conjunctive: neither a domicile nor a tax liability, across the last three calendar years — full years, not a rolling 36 months. Note that this paragraph says "tax liability" without qualification; the second paragraph is where the statute narrows what kind of liability actually disqualifies.

Paragraph 2 — the carve-out for prior investment income

"Birinci fıkra kapsamındaki gerçek kişilerin bu madde kapsamına girmeden önce, Türkiye'de elde ettiği gayrimenkul sermaye iradı, menkul sermaye iradı veya değer artışı kazancı nedeniyle mükellefiyetinin bulunması bu istisnadan yararlanmasına engel teşkil etmez."

Translation: The fact that a natural person within the scope of the first paragraph had, before coming within the scope of this Article, a tax liability in Türkiye by reason of immovable-property income, movable-capital income, or capital gains does not prevent them from benefiting from this exemption.

What it does: this is the clause most English coverage gets wrong or omits. Owning and renting out Turkish property, holding Turkish securities, or realizing gains on Turkish assets as a non-resident — the classic limited-liability footprint — does not poison the lookback. The foreign investor with an Antalya flat qualifies. What the carve-out conspicuously does not protect: full-taxpayer status, or commercial and professional activity. The three protected categories are named exhaustively, not illustratively.

Paragraph 3 — no return, no inclusion

"Birinci fıkra kapsamındaki kazanç ve iratlar için yıllık beyanname verilmez, diğer gelirler nedeniyle beyanname verilmesi halinde de bu gelirler beyannameye dahil edilmez."

Translation: No annual return is filed for the earnings and revenues within the scope of the first paragraph; where a return is filed on account of other income, these revenues are likewise not included in that return.

What it does: the exemption is administratively silent — exempt foreign income isn't declared at all, even when you file a Turkish return for (say) Turkish rental income. That's cleaner than "report-but-exempt" regimes elsewhere. And because eligibility gets tested outside the return itself, Communiqué No. 333 built the testing point up front: a tax-office application (form EK-1) and an exemption certificate, the , due by the end of your first residency year.

Paragraphs 4 and 5 — no deductions, no foreign tax credit

"İstisna kapsamındaki kazanç ve iratlara ilişkin gider ve maliyetler, vergiye tabi kazanç ve iratların tespitinde dikkate alınmaz."

Translation: Expenses and costs relating to the exempt earnings and revenues are not taken into account in determining taxable earnings and revenues.

"Bu istisna kapsamındaki kazanç ve iratlar nedeniyle yabancı memleketlerde ödenen vergiler Türkiye'de tarh edilen gelir vergisinden mahsup edilemez."

Translation: Taxes paid in foreign countries on the earnings and revenues within the scope of this exemption may not be credited against income tax assessed in Türkiye.

What they do: the exemption walls its income off completely — costs on the exempt side can't shelter the taxable side, and foreign withholding on exempt income is simply a final cost, with nothing in Türkiye to credit it against. That second rule inverts ordinary cross-border planning: under 20/D, minimizing source-country tax is the entire game. We walk through the consequences in the Beckham-vs-7582 comparison.

Paragraph 6 — the penalty for getting it wrong

"İstisnaya ilişkin şartların taşınmadığının sonradan tespit edilmesi halinde tahakkuk ettirilmeyen vergiler, ziyaa uğramış sayılır."

Translation: If it is subsequently determined that the conditions for the exemption were not met, the taxes that were not assessed are deemed to have been lost.

What it does: "deemed lost" invokes vergi ziyaı — Türkiye's tax-loss concept, which brings the loss penalty (typically the tax itself again), late-payment interest, and assessment of the original tax. In plain terms: claim the exemption on a dirty lookback and the downside isn't repaying the difference — it's the evasion-grade penalty track, potentially across many years of a twenty-year window.

Paragraph 7 — the communiqué authority

"Hazine ve Maliye Bakanlığı bu maddenin uygulanmasına ilişkin usul ve esasları belirlemeye yetkilidir."

Translation: The Ministry of Treasury and Finance is authorized to determine the procedures and principles regarding the application of this Article.

What it does: this single sentence is where every open question lived — and on 4 July 2026 the Ministry used it. Income Tax General Communiqué No. 333 (Official Gazette No. 33300) is the implementing text issued under this authority, and it decided, as predicted, more real-world outcomes than the rest of the article combined: an application-and-certificate claim procedure with a hard deadline, the strict sourcing of services performed in Türkiye (its Example 10), and the exact reach of the paragraph-2 carve-out (Examples 4–7). The full breakdown is in the main guide's claiming section.

Article 2 of Law 7582 — the 1% inheritance companion

"31/12/1960 tarihli ve 193 sayılı Gelir Vergisi Kanununun mükerrer 20/D maddesi kapsamında gelir vergisi istisnasından yararlananlardan, mezkûr istisna için öngörülen süre dâhilinde gerçekleşen veraset yoluyla mal intikalinde vergi oranı %1 olarak uygulanır."

Translation: For those benefiting from the income tax exemption under mükerrer Article 20/D of the Income Tax Law No. 193 of 31/12/1960, the tax rate on transfers of property by inheritance occurring within the period prescribed for the said exemption shall be applied as 1%.

What it does: inserted into Article 16 of the Inheritance and Transfer Tax Law, this pins inheritance transfers at a flat 1% — versus the ordinary progressive scale that climbs by tranche to 10% — for as long as the beneficiary enjoys the 20/D exemption. Note what it covers: transfers by inheritance (veraset yoluyla). Lifetime gratuitous transfers, taxed on a separate and higher scale, are not mentioned.

Article 14(a) — entry into force and the 2026 retroactivity

"Bu Kanunun; a) 4 üncü maddesi, 1/1/2026 tarihinden itibaren Türkiye'ye yerleşmiş sayılanlara uygulanmak üzere yayımı tarihinde, [...] yürürlüğe girer."

Translation: Article 4 of this Law enters into force on the date of its publication, to be applied to those deemed settled in Türkiye from 1 January 2026 onward.

What it does: the retroactivity clause. Anyone who became a Turkish tax resident on or after 1 January 2026 — five months before the law existed — is inside the regime, with their covered from the start of the year. The eligibility mapper applies this automatically when your residency year computes to 2026.

What the statute doesn't say

Reading the text is also about noticing its silences — and watching which ones the Ministry chose to fill. When this page first published, the statute prescribed no application procedure, didn't source remote work, didn't link to permit categories, and didn't address requalification. Communiqué No. 333 has since filled the first two: the exemption is claimed by a deadline-bound tax-office application (EK-1 → İstisna Belgesi), and work physically performed in Türkiye is Turkish-source even for foreign clients (Example 10). Still genuinely silent, in both statute and communiqué: any residence-permit linkage (the claim runs entirely through the tax office), requalification for a second window after leaving, and crypto sourcing. Those blanks still belong to the Ministry — which is why this page and the main guide keep getting updated, announced first in The Border Brief.

Sources: Law No. 7582, Official Gazette No. 33270, 4 June 2026; Income Tax General Communiqué No. 333, Official Gazette No. 33300, 4 July 2026. Unofficial translation; the Turkish text controls. Analysis, not tax or legal advice — full disclaimer.

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