Recent Developments
Law No. 7582 on the Amendments to Certain Laws (“Law“), which was adopted by the General Assembly of the Grand National Assembly of Türkiye on 21 May 2026 but has not yet been published in the Official Gazette, introduces a new asset peace application through provisional Article 19 added to Corporate Income Tax Law No. 5520.
The regulation allows real persons and legal entities to declare and record their unrecorded money, gold, foreign currency, securities and other capital markets instruments located abroad or in Türkiye, subject to tax at specified rates.
The new asset peace application is largely similar to previous regulations; however, it differs from prior practices through its graduated tax rate system, under which the tax rate may decrease to as low as 0% if the declared assets are committed to be kept in Türkiye for specified periods, as well as through the opportunity to invest such declared assets in venture capital investment funds.
What Do the Amendments Introduced by the Decree Mean?
Assets Within the Scope
The asset peace covers money, gold, foreign currency, securities and other capital markets instruments held abroad, or held in Türkiye but not recorded in the statutory books of income or corporate income tax taxpayers. Real estate and other assets are excluded from the scope of the regulation.
There is no need to separately prove that the assets existed at an earlier date; bringing them to Türkiye or recording them in the books within the prescribed periods is sufficient.
Persons Eligible to Benefit from the Asset Peace
The asset peace application may be benefited from by real persons and legal entities (companies, foundations and similar), including:
- Income and corporate income tax taxpayers;
- Persons not subject to bookkeeping obligations; and
- Real persons without any tax registration in Türkiye.
Notification Process and Requirement to Bring to Türkiye
Persons wishing to benefit from the asset peace application must notify the assets within the scope to banks or intermediary institutions in Türkiye by 31 July 2027. The President is authorized to extend this period, in periods not exceeding six months each from the expiry date, by up to one year.
Assets located abroad and within the scope of the regulation must be:
- transferred to accounts opened in the names of the relevant persons at banks or intermediary institutions in Türkiye; or
- where physically brought from abroad, deposited in such accounts
within two months from the notification date.
The bringing into Türkiye of physically transported assets shall be evidenced through documents related to the declaration to be made to the Customs Administration; the Customs Administration shall notify the Revenue Administration of declarations received in this context by the end of the month following the month of receipt.
Assets located in Türkiye but not recorded in the books must be evidenced by being deposited at banks or intermediary institutions as of the notification date.
Tax Rates
Banks and intermediary institutions shall, in their capacity as tax responsible, declare the tax that they have collected in advance from the notifier through a declaration to be filed with their relevant tax office by the evening of the fifteenth day of the month following the notification, and shall pay such tax within the same period.
The general tax rate is 5%; however, the tax rate decreases gradually depending on the period for which the notified assets will be kept in time deposit accounts, in government domestic debt securities and lease certificates issued under Law No. 4749, or in venture capital investment funds:
| Period of Commitment | Tax Rate |
| At least 5 years | 0% |
| At least 4 years | 1% |
| At least 3 years | 2% |
| At least 2 years | 3% |
| At least 1 year | 4% |
| No commitment (General rate) | 5% |
In addition, the above rates increase by half a percentage point for notifications made between 1 January 2027 and 31 July 2027 (inclusive). If the President extends the 31 July 2027 deadline, the rates rise by a further half percentage point for notifications made thereafter, bringing the total increase to one percentage point. Furthermore, no stamp tax is levied on the commitment letters provided under this scope.
Recording of Declared Assets
Assets that are the subject of notification shall be recorded in the statutory books of taxpayers subject to bookkeeping obligations under Tax Procedural Law no. 213 as of the notification date. The recording principles have been arranged as follows:
- Taxpayers keep their books on a balance sheet basis: A special fund account shall be opened on the liabilities side for the values recorded. This fund account may not be withdrawn from the business until two years have lapsed from the notification date, may not be used for any purpose other than transfer to share capital, and shall not be subject to tax in the event of liquidation of the business.
- Taxpayers keep their books on self-employment income basis or simplified account basis: Such values shall be separately shown in their books. These assets shall not be taken into consideration in the determination of period income and may be withdrawn from the business without being taken into consideration in the determination of taxable income and (for corporate taxpayers) distributable income, provided that two years have lapsed from the notification date.
- Persons without income or corporate income tax liability: Where such persons bring the notified assets into Türkiye within the prescribed periods and substantiate their domestic assets by depositing them at banks or intermediary institutions as of the notification date, they may benefit from the provisions of the article without being required to satisfy the bookkeeping conditions.
Advantages and Limitations of Benefiting from the Regulation
No tax inspection or tax assessment shall be conducted in any manner with respect to the amounts corresponding to the assets declared within the scope of the asset peace. However, measures required to be taken under other legislation, such as the Law on the Protection of the Value of Turkish Currency, the Capital Markets Law, the Customs Law and the Anti-Smuggling Law, will not be affected by this regulation. Accordingly, the new asset peace application provides only an assurance that no tax inspection or assessment will be conducted; therefore, obligations under other legislation continue to apply.
The following principles will apply in respect of any tax base difference identified as a result of tax inspections initiated for other reasons or valuation commission decisions:
- Where the tax base difference arises from the declared assets and the declared amount equals or exceeds such difference, no tax assessment shall be made on the said tax base difference.
- Where the tax base difference arises from the declared assets but exceeds their amount, tax assessment shall be made only on the excess.
- Where the tax base difference arises from reasons other than the declared assets, the declared amounts shall not be offset against such difference, and tax assessment shall proceed.
Finally, the taxes paid under this regulation cannot be recorded as an expense in any manner and cannot be offset against any other tax. In addition, losses arising from the disposal of assets subject to notification shall not be accepted as expenses or deductions for income or corporate income tax purposes.
Conclusion
The new asset peace application, which will enter into force on the date the Law is published in the Official Gazette, is generally similar to the previous applications in terms of its overall framework; however, it differs through its graduated tax rate system, under which the tax rate may be reduced to as low as 0% depending on the commitment to keep the declared assets in Türkiye for specified periods, as well as through the possibility of investing such declared assets in venture capital investment funds. In this respect, the regulation appears to be aimed not only at bringing unrecorded assets into the system, but also at encouraging such funds to be held within the Turkish financial system for a longer period. Notably, the new asset peace application is expected to strengthen the flow of resources by encouraging investments in venture capital investment funds and to contribute to the development of local entrepreneurship ecosystem.
On the other hand, since the protection under the regulation is limited solely to tax inspection and assessment, it is important that real persons and legal entities considering the application also conduct a separate evaluation, particularly with respect to foreign exchange, capital markets, customs and anti-money laundering legislation.
