New Asset Amnesty Regulation

A new asset amnesty regulation has entered into force under Provisional Article 19, added to Corporate Income Tax Law No. 5520 by Law No. 7582 on Amendments to Certain Laws, published in the Official Gazette No. 33270 dated June 4, 2026.

The regulation aims to facilitate the repatriation of certain financial assets located abroad to Türkiye and to bring certain assets located in Türkiye but not recorded in statutory books into the legal system.

Eligible Persons and Assets

Both individuals and legal entities may benefit from the asset amnesty regulation. With respect to assets located abroad, the Law does not impose any additional citizenship or tax liability requirement.

The following assets may be subject to notification under the regulation:

• cash, gold, foreign currency, securities and other capital market instruments located abroad;
• cash, gold, foreign currency, securities and other capital market instruments located in Türkiye that belong to income or corporate taxpayers but are not recorded in their statutory books.

Notification Period and Main Conditions

Assets located abroad must be notified to a bank or brokerage firm operating in Türkiye by no later than July 31, 2027. The notified assets must be transferred, within two months from the notification date, to accounts opened in the name of the notifying person at a bank or brokerage firm in Türkiye; or, where assets are physically brought into Türkiye, they must be deposited into such accounts.

As for assets located in Türkiye but not recorded in statutory books, such assets must also be notified to banks or brokerage firms by no later than July 31, 2027, and must be substantiated by being deposited with such banks or brokerage firms as of the notification date.

Assets notified by taxpayers who keep statutory books must also be recorded in their statutory books. For taxpayers keeping books on a balance sheet basis, a special fund account must be opened on the liabilities side for these assets. This fund account may not be withdrawn from the business until two years have elapsed from the notification date and may not be used for any purpose other than capital increases. Upon the expiry of this period, however, the relevant assets may be withdrawn from the business without being taken into account in the determination of taxable income or, for corporations, distributable profit.

Tax Consequences and Rates

As a general rule, a 5% tax is calculated on the assets notified under the Law. However, lower tax rates will apply if a commitment is made to hold the notified assets in certain investment instruments for specified periods.

The rates applicable where the notified assets are held in term deposit accounts, government domestic debt securities, lease certificates or venture capital investment funds are as follows:

In addition, a half-point increase will apply to these rates for notifications made between January 1, 2027 and July 31, 2027. If the notification period is extended by the President, the rates will apply with a total increase of 1 percentage point for notifications made during the extended period.

Tax Audit and Assessment Protection

No tax audit or tax assessment will be conducted with respect to the amounts corresponding to assets notified in accordance with the conditions set out in the Law.

However, this protection is not unlimited. If a tax base difference is identified for reasons other than the notified assets, the notified amounts will not be automatically offset against such difference. In addition, it will not be possible to benefit from this protection for notifications made after the initiation of a tax audit or after referral to the tax assessment commission.

Failure to comply with the transfer, substantiation, tax payment and investment commitment conditions stipulated under the Law will also result in the loss of protection against tax audits and tax assessments.

Conclusion

The new asset amnesty regulation offers a significant opportunity for bringing financial assets located abroad into Türkiye and integrating certain unrecorded assets into the legal system.

The most significant feature distinguishing this regulation from previous asset amnesty practices is that the tax rate gradually decreases depending on the period during which the notified assets are held in specified investment instruments, and may decrease to zero with a five-year commitment.

However, in order to benefit from the regulation, the conditions regarding notification, transfer, substantiation, registration, tax payment and investment commitment must be carefully fulfilled.

Although a draft communiqué regarding the procedures and principles of implementation has been prepared by the Turkish Revenue Administration, as of the date of this article, the final communiqué has not yet been published.

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