Guide to Acquiring Turkish Citizenship Through Real Estate Investment for Chinese Investors | Izmir Immigration Lawyer

As Baykal Law Firm (www.baykal.av.tr), we provide professional legal consultancy and advocacy services to foreign investors in Izmir and throughout Turkey for real estate acquisition and exceptional Turkish citizenship processes.

1. Introduction and the Legal Framework of Citizenship by Investment

The Republic of Turkey offers various paths to acquire exceptional citizenship under the Turkish Citizenship Law No. 5901 to encourage foreign direct investment and bring foreign currency into the country’s economy. Pursuant to Article 20, paragraph 2, subparagraph (b) of the relevant legislation, foreigners who purchase real estate worth at least 400,000 USD (or equivalent foreign currency) and place a three-year no-sale annotation on the title deed can acquire Turkish citizenship by the decision of the President. This opportunity is a comprehensive family citizenship program that covers not only the main investor but also their spouse and children under the age of eighteen.

For Chinese investors who wish to bring their families to Turkey and start this process, it requires a multi-step bureaucratic procedure coordinating finance, real estate law, administrative law, and immigration law. Conducting these procedures at administrative authorities in and around Izmir (such as the Izmir Provincial Directorate of Population or the Directorate of Migration Management) accompanied by an expert immigration lawyer prevents irreversible loss of rights. Technical details that are frequently confused in practice, such as the “Foreign Exchange Purchase Document” (DAB) and the “Certificate of Conformity” (Real Estate Investment Determination Document), require meticulous legal follow-up.

In this guide, we analyze step-by-step all the administrative and legal processes for our Chinese clients, starting from opening a bank account in Turkey, choosing the real estate to invest in, operating the payment mechanism (DAB), establishing a short-term residence permit under Article 31/1-(j) of Law No. 6458, and finally applying for citizenship at the Izmir population directorates.

2. Bank Account Opening and Tax Number for Foreigners in Turkey

The foundation of the citizenship application process is integrating the minimum investment capital of 400,000 USD into Turkey through legal banking channels. According to Turkish legislation, there is no provision preventing foreign real persons from opening a bank account in Turkey. However, strict rules apply in accordance with the Law on Prevention of Laundering Proceeds of Crime No. 5549 and the related MASAK (Financial Crimes Investigation Board) regulations.

2.1. Obtaining a Potential Tax Identification Number (VKN)

Foreigners must obtain a “Potential Tax Identification Number” for opening a bank account, purchasing real estate, and other transactions requiring tax liability in Turkey. This can be done in person at tax offices in Izmir, or electronically in seconds through the Digital Tax Office portal with the help of your lawyers. This number will continue to be used as a permanent tax number if the foreigner engages in commercial activities in Turkey or acquires citizenship in the future.

2.2. Bank Account Opening Process and MASAK Compliance Principles

To open demand deposit accounts in foreign currency and Turkish Lira, it is mandatory to confirm the customer’s identity, address, and the purpose of the transaction in accordance with MASAK General Communiqués. The minimum required document set for opening a bank account is as follows:

Required Document/Information	Legal Basis and Function
Valid Passport	Sworn translator approved and notarized Turkish translation.
Potential Tax Number	Integration of financial transactions with the taxation system.
Address Verification Document	A utility bill or lease agreement issued in the person’s name within the scope of MASAK.
Turkish GSM Number	Required for internet banking and SMS password transmission.

The Role of the Lawyer: Address verification in Turkey and the deposit (blockage) requirements applied by some banks for foreigners without a Foreign Identity Number (YKN) can slow down the process. As Baykal Law Firm, we accelerate the processes in bank compliance departments on behalf of our clients through legal petition letters stating that the account is being opened within the scope of “Turkish Citizenship by Investment”.

3. Property Selection and Legal Due Diligence

Acquiring citizenship is subject to much stricter rules than an ordinary real estate purchase and sale transaction. It is vital to conduct a legal due diligence on the property before the client makes any payments.

3.1. “Foreigner to Foreigner” Sale Ban and Encumbrances

It is an absolute requirement that the owner of the property to be purchased must be a Turkish citizen or a company registered in the Turkish trade registry. Furthermore, if the property was previously used by another foreign investor to acquire citizenship, it cannot be included in a second citizenship application.

The property must not have any precautionary injunctions, execution attachments, or legal mortgages that could cause a change in ownership. Since there is an obligation to submit a project within 2 years for land-qualified properties, preferring completed properties with an occupancy permit (iskan) generally minimizes legal risks.

3.2. 2024 Reform in Real Estate Valuation (Appraisal) Rules

The minimum amount of 400,000 USD must be confirmed by an independent valuation report. With the Circular dated March 4, 2024 (Circular No. 2024/2) issued by the Ministry of Environment, Urbanization and Climate Change, it is now mandatory that the valuation reports required for exceptional citizenship are issued exclusively by GEDAŞ Gayrimenkul Değerleme A.Ş., a subsidiary of TOKİ.

The period from the date of the report to the title deed application must not exceed 3 months, and the amount determined over the Central Bank’s effective selling rate must absolutely exceed the 400,000 USD limit.

4. Payment Process and Foreign Exchange Purchase Document (DAB)

The “Foreign Exchange Purchase Document” (DAB) application is a mandatory rule in the payment process. The process works as follows:

1. Currency Exchange: The investment amount (at least 400,000 USD) must be exchanged into TL by selling it to the Central Bank of the Republic of Turkey (CBRT) through an intermediary Turkish bank before the title deed application.
2. Issuance of DAB and KEP Transmission: The bank transmits the DAB, stating that the foreign currency was exchanged for citizenship purposes, directly to the General Directorate of Land Registry and Cadastre (TKGM) via the KEP system.
3. TL Transfer: The obtained Turkish Lira is transferred from the buyer to the seller via EFT/Wire Transfer, and the passport/title deed information is annotated on the receipt.

Whether the investment amount meets the 400,000 USD requirement is determined not by the exchange rate on the day of the title deed transfer, but strictly by the Central Bank exchange rate on the date the DAB was issued.

The DAB value, the value in the Appraisal report, and the sales price in the Official Deed (Title Deed) must be consistent with each other and meet the 400,000 USD requirement.

5. Transfer Process at Izmir Title Deed Offices and the 3-Year Annotation

The following documents are required for the transaction to be carried out in Izmir or at the relevant Title Deed Registry Office where the real estate is located:

Documents Required for Title Deed Transfer	Function
Title Deed, Real Estate Fair Value Document, DASK	Registry of the property and mandatory paperwork.
Original Passport and Translation	Confirmation of identity and nationality.
GEDAŞ Valuation Report, DAB and Receipts	Proof that the investment limit is exceeded and TL transfer is made.
Sworn Translator	Mandatory for a buyer who does not speak Turkish.

During the signing of the official deed, the following annotation is placed on the title deed registry: “I commit not to sell this immovable property/properties that I have acquired for the purpose of obtaining Turkish Citizenship within the scope of Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law for a period of 3 years”.

6. Obtaining the Real Estate Investment Conformity Certificate

After the annotation process at the title deed office, the files are forwarded to the commissions affiliated with the Ministry of Environment, Urbanization and Climate Change. Following the administrative approval mechanism, the issued “Certificate of Conformity” (Real Estate Investment Determination Document) is sent to the Directorate of Migration Management and the Directorate of Population via KEP. Receiving this document officially starts the immigration law phase of the citizenship application.

7. Short-Term Investor Residence Permit Under YUKK Article 31/1-(j)

Individuals applying for citizenship by investment must obtain an “Investor Residence Permit” in accordance with Article 31/1-(j) of Law No. 6458 (YUKK).

• Status of Family Members: There is no need to make a separate investment or obtain separate (J) clause residence permits for the Chinese client’s spouse and children under 18. The entire family is included in the citizenship file through the main investor’s permit.
• Izmir Provincial Directorate of Migration Application: The application must be made in person as fingerprinting is mandatory. The process is completed with a Passport, Certificate of Conformity, Private Health Insurance, Biometric photographs, and Fee receipts, defining a Foreigner Identity Number (YKN) for the client.

8. Turkish Citizenship Application to the Izmir Provincial Directorate of Population

In the final stage, the physical file is delivered to the Izmir Provincial Directorate of Population and Citizenship. At this stage, the authentication status of documents brought from China is particularly important.

8.1. Apostille Revolution in Chinese Documents

With the People’s Republic of China becoming a party to the Hague (Apostille) Convention as of November 7, 2023, the requirement for consular legalization has been abolished. Birth certificates (Hukou) and marriage certificates brought from China will be brought to Turkey with an “Apostille” annotation obtained from the Chinese competent authorities, and become ready for use here with sworn translation and notary approval. It is mandatory that the day, month, and year information on birth dates are completely stated.

8.2. Approval Process of the Citizenship File (VAT-4)

The file to be submitted to the population directorate includes the following documents: VAT-4 application form, translated passports, apostilled birth and marital status documents, birth registration copy, fee receipts, residence card, and investment documents.

In case the in-depth security investigation conducted by the National Intelligence Organization (MİT) and the General Directorate of Security yields positive results, the file is presented to the Presidency. The ultimate discretion and approval belong to the President.

Why Do You Need an Immigration Lawyer?

The Turkish citizenship application process is an administrative procedure subject to highly strict rules and leaves no room for error, operated in coordination with the Ministry of Treasury and Finance, General Directorate of Land Registry and Cadastre, Directorate of Migration Management, and the Directorate of Population.

• Inspecting whether the property to be purchased falls under the “Foreigner to Foreigner” ban in the past,
• Executing GEDAŞ Valuation and DAB transactions flawlessly, down to the exact penny and in the correct order,
• Speeding up the process through specially authorized power of attorney documents without the need to be personally present

are assurances that only law firms specialized in this field can provide. As Baykal Law Firm (www.baykal.av.tr), we manage your citizenship by investment processes from end to end, transparently and completely. You can reach our expert team from our contact page.

Phone: +90 506 128 95 95

Email: av.yasinbaykal@agmail.com