Turkey Changed its Citizenship Investment Scheme: Here’s the Update…

Turkey has an interesting CIP. It’s one of the more interesting programs in Europe, since it offers direct citizenship.

However, there were certain loopholes in its regulations. Those loopholes allowed investors to use the same property more than once to register different investors.

Turkey has changed that. As of March 2021, a single estate is usable only once for citizenship qualification.

The changes were done to Turkey’s official citizenship law guidelines.

What Do The Guidelines Include?

A new guideline was introduced titled “Transactions between Foreigners,” which added more requirements for both the property and the buyer.

Those guidelines apply to sales and preliminary agreements. They include the following:

  • Properties that were transferred to Turkish companies/citizens before January 12th 2017 do not qualify. The property still doesn’t qualify if it was transferred to a children/spouses of the investor, or to a foreigner of a similar nationality.
  • Property listed at the land registry under foreign persons (including investor children and spouses) do not qualify.

The only exception is if the property transfer was from the foreigner to a Turkish company/citizen before Jan 12th 2017. From there, a foreigner with a differing nationality can invest in that property, and use it to apply for citizenship.

Also, if a property (under a preliminary sales agreement or sale) is transferred to a foreigner, it shouldn’t be registered for:

  • Companies managed (or owned in part) by the same foreigner, their children, or spouse.
  • Companies governed by the Land Registry’s Law (Article 36), where one of the company’s partners holds the same nationality as the foreigner.

A property can’t be used to get another citizenship if it was originally transferred via a preliminary sales contract of title deed.

Here’s an Example to Illustrate.

Let’s say a foreigner (we’ll call him Mr. X) decides to buy property. They just finalized a sales contract to buy all shares in a Turkish estate at $300,000 USD.

After finalizing the deal, they might undertake to not release or sell the estate for the next 3 years. They then annotate the estate at the Land Registry.

At that point, Mr. X qualifies for a conformity certificate.

However, after the 3 year timeframe passes, even if a new owner buys that property from Mr. X, that same property cannot be used to gain Turkish citizenship a second time.

The same rule applies if Mr. X had bought a partial share of the estate (instead of buying into it fully). If they transfer those shares to another foreigner, that foreigner cannot use them to apply for citizenship.

As for Selling Back the Same Property.

If the property gets sold by to the same company or person whom originally owned it – then the conformity certificate received by Mr. X gets re-evaluated (possibly revoked).

That same re-evaluation applies if Mr. X revokes annotating the sales contract at the land registry, then sells the estate to a third individual.

In Summation

The Turkish government is ensuring that investors do not loop property without truly contributing to the economy.

It ensures that those using property to sign up are actually investors, not individuals taking advantage of an old loophole for quick immigration.