REGULATORY

Tax Residency Rules in Türkiye: What Uzbek Investors Need to Know

How Türkiye's tax residency rules, the 183-day test, and the Uzbekistan treaty affect Uzbek investors buying property or running projects.

February 5, 2026·5 min read
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Uzbekistan's outbound investors evaluating Turkish real estate and construction assets increasingly ask the same question at the diligence stage: what does owning property or running a project company in Türkiye actually mean for their personal tax residency, and does it create exposure back home. The answer depends on how much time is spent in-country, how income is structured, and whether the two tax systems talk to each other under existing treaty arrangements.

Residency Triggers Under Turkish Law

Türkiye determines individual tax residency primarily through two tests: physical presence of more than six months (183 days) within a calendar year, or having a registered domicile (a permanent home available for use) in Türkiye. Foreign nationals who buy an apartment in Istanbul or a villa on the Aegean coast but visit only occasionally do not automatically become tax residents. Ownership of property alone is not a residency trigger. What matters is settled presence: continuous stays, a centre of vital interests, or formal registration of address with local authorities that signals intent to live in Türkiye rather than simply hold an asset there.

Uzbek investors who plan to manage a construction project on-site, oversee a joint venture, or run day-to-day operations of a local company should expect closer scrutiny. Extended stays tied to active management functions, rather than passive ownership, are the pattern Turkish tax authorities look at most carefully.

Double Taxation : Türkiye and Uzbekistan maintain a bilateral double taxation avoidance agreement, which is a material advantage for investors structuring cross-border holdings. The treaty allocates taxing rights between the two states and provides relief mechanisms, typically credit or exemption methods, so that rental income, capital gains, or business profits are not taxed twice on the same base. Investors should still confirm current treaty terms with a qualified tax advisor before closing a transaction, since treaty application depends on the specific income type and how the holding structure is set up.

Corporate Versus Personal Exposure

Many Uzbek investors entering Turkish real estate or construction use a locally incorporated company rather than direct personal ownership, for reasons of liability, financing access, and operational control. This choice has tax residency implications distinct from personal residency. A Turkish-incorporated company is generally treated as a Turkish tax resident entity regardless of where its shareholders live, meaning corporate profits are subject to Turkish corporate tax. The individual shareholder's personal residency status is a separate question, governed by the presence and domicile tests described above, not by the company's registration.

This separation is useful for structuring: an investor can hold a Turkish operating company and remain a non-resident individual for Turkish personal tax purposes, provided actual time spent in-country and domicile arrangements stay within the applicable thresholds. Conflating corporate and personal residency is one of the more common structuring errors seen among first-time foreign investors.

Citizenship-Linked Investment

Türkiye's real estate-linked citizenship program is a separate legal track from tax residency and should not be confused with it. Acquiring citizenship through qualifying investment does not by itself create Turkish tax residency; the same presence and domicile tests apply to naturalized citizens who do not actually live in Türkiye. Investors evaluating this path should treat it as a citizenship decision with its own criteria, not a shortcut around residency planning.

Practical Steps Before Closing

Before finalizing a property purchase or forming a project entity in Türkiye, Uzbek investors should map out expected time in-country against the 183-day threshold, decide whether personal or corporate ownership better suits the investment horizon, and review how the bilateral tax treaty applies to the specific income streams involved, whether rental, development profit, or capital gains on exit. Engaging Turkish tax counsel alongside a local real estate advisor early in the process avoids restructuring costs later and ensures the ownership vehicle matches both the investment strategy and the investor's residency intentions.

Getting this sequencing right at the outset, rather than after a transaction has closed, remains the most reliable way to avoid unplanned tax exposure in either jurisdiction.

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