Tax residence in Türkiye for U.S. citizens and green card holders

Türkiye treats you as settled there, and fully liable on income earned in and outside Türkiye, if your domicile — the place where you live with the intention of remaining permanently — is in Türkiye or you stay there continuously for more than six months in a calendar year, temporary departures not interrupting the stay (art. 4 of the Gelir Vergisi Kanunu). Foreigners who come for a definite and temporary assignment or job, study, medical treatment, rest or travel are not settled even after six months (art. 5). The United States taxes its citizens and green card holders as residents wherever they live, and other individuals under the substantial presence test (183 weighted days over three years, with at least 31 in the current year). A dual residence is resolved under Art. 4(2) of the 1996 U.S.–Turkey Convention: permanent home, center of vital interests, habitual abode (also when you have a permanent home in neither country), nationality, then mutual agreement. The saving clause (Art. 1(3)) keeps U.S. tax on citizens — and on former citizens for ten years — whatever the result.

Check your status: United States and Türkiye

Free, no sign-up, about 3 minutes. Conclusion under U.S. law, compared with the law of Türkiye and the tax treaty.

When Türkiye treats you as a tax resident

Türkiye has two grounds for full tax liability: being settled in Türkiye, or being a Turkish citizen abroad in the service of a Turkish public body or of an enterprise headquartered in Türkiye. Türkiye's tax year is the calendar year.

The Turkish Revenue Administration accepts that Turkish citizens who have lived abroad for more than six months with a work or residence permit are domiciled in the country where they live. Then only the six-month rule can make them fully liable in Türkiye.

A person who stays in Türkiye continuously for more than six months in a calendar year is settled in Türkiye; temporary departures do not interrupt the stay. More than 183 days of actual presence meets this test; with fewer days, a stay of more than six months counting temporary departures may also be enough.

The exception in art. 5 GVK applies only to foreigners and overrides the six-month rule.

As a Turkish citizen you are abroad in the service and on the business of a Turkish public body or of an enterprise headquartered in Türkiye — under art. 3(2) GVK you are fully liable in Türkiye. Income that is subject to income tax or a similar tax in the country where you are is not taxed again in Türkiye.
Your domicile (the place where you live with the intention of remaining permanently) is in Türkiye — under art. 4(1) GVK you are settled in Türkiye and fully liable on your worldwide income.
You stayed in Türkiye continuously for more than six months in this calendar year — under art. 4(2) GVK you are settled in Türkiye and fully liable on your worldwide income.

When you are a nonresident

Your domicile is not in Türkiye and you did not stay there for more than six months in this calendar year — you are a limited taxpayer: Türkiye taxes only income earned in Türkiye (arts 6–7 GVK).
Although you stayed in Türkiye for more than six months, you are a foreigner there for a temporary assignment or job, study, medical treatment, rest or travel, or for reasons beyond your control — under art. 5 GVK you are not settled in Türkiye and are a limited taxpayer.

Where the rules of Türkiye clash with U.S. tax rules

Collision: domicile keeps you settled in Türkiye while the U.S. taxes you as citizen or resident. Türkiye treats you as fully liable as long as your domicile — the place where you live with the intention of remaining permanently — is in Türkiye, however few days you spend there. If the United States also treats you as resident (citizenship, green card or substantial presence), Art. 4(2) of the U.S.–Turkey Convention decides: permanent home; with a home in both countries, centre of vital interests; if that cannot be determined, or you have a permanent home in neither, habitual abode; then nationality; then mutual agreement. A U.S. citizen remains taxable in the U.S. whatever the result (Art. 1(3)).
Collision: more than six months in Türkiye while resident in the U.S.. A continuous stay of more than six months in a calendar year makes you settled in Türkiye. In the same year you may still be a U.S. resident — as a citizen or green-card holder in any case, or under the substantial presence test in the year you move. Art. 4(2) of the Convention then decides which country is your treaty residence; ask the Turkish tax office for a certificate of residence if Türkiye is. If you are not a U.S. citizen and Türkiye wins, you file in the U.S. as a nonresident (Form 1040-NR with Form 8833).

What else to know

Which treaty applies: the 1996 U.S.–Turkey Convention. The Convention and Protocol signed at Washington on 28 March 1996 entered into force on 19 December 1997 and apply generally from 1 January 1998. Türkiye signed the MLI but has not ratified it, and the United States is not a party, so the Convention is not modified by it. Residence tie-breaker: Art. 4(2) — permanent home → centre of vital interests → habitual abode (also when you have a permanent home in neither country) → nationality → mutual agreement; Protocol para. 1 applies these rules to nationals of either country. Saving clause: Art. 1(3), including former U.S. citizens for ten years; employment: Art. 15 (183 days in any continuous 12 months); social security payments: Art. 18(2); relief: Art. 23 (Türkiye credits U.S. tax; Art. 23(3) for U.S. citizens resident in Türkiye); mutual agreement: Art. 25.
Counting periods: calendar year in both countries, but different tests. Both countries use the calendar year, but they count differently: the United States adds all days in the U.S. this year plus weighted days of the two prior years (substantial presence test); Türkiye's six-month test looks at a continuous stay of more than six months within one calendar year, and temporary departures do not interrupt it. Türkiye also treats you as settled whenever your domicile is in Türkiye, whatever the days. The 183-day limit for salary in Art. 15(2)(a) of the Convention counts days in any continuous 12-month period.
Turkish citizen living in the U.S. with a residence permit: limited taxpayer in Türkiye. The Turkish Revenue Administration accepts that a Turkish citizen who has lived abroad for more than six months with a work or residence permit is domiciled abroad and taxed in Türkiye only on Turkish-source income. Türkiye will treat you as fully liable again if you return permanently or stay in Türkiye for more than six months in a calendar year.
U.S. citizens resident in Türkiye: the saving clause and the Turkish credit. Under the saving clause (Art. 1(3)) the United States keeps taxing a U.S. citizen as if the Convention did not exist; relief from double taxation (Art. 23) is one of the exceptions in Art. 1(4). As a Turkish resident you credit U.S. income tax paid in accordance with the Convention against Turkish income tax (Art. 23(2); art. 123 GVK), up to the Turkish tax on the income that may be taxed in the U.S.; you prove the payment with documents from the U.S. authorities certified by a Turkish consulate. For U.S. tax charged only because of citizenship, Art. 23(3) sets special source and credit rules; the U.S. foreign tax credit and exclusion are covered in the U.S. section.
Working in Türkiye while resident in the U.S. (Art. 15(2)). Pay for work physically done in Türkiye is Turkish-source income. If the United States is your treaty residence, Türkiye does not tax it only if all conditions of Art. 15(2) of the Convention are met: not more than 183 days in Türkiye in any continuous 12-month period, an employer that is not resident in Türkiye, and pay not borne by a permanent establishment or fixed base of the employer in Türkiye. Otherwise Türkiye taxes the pay for your Turkish work days and the United States credits the Turkish tax.
Moving to Türkiye: 20-year exemption for foreign income. If you become settled in Türkiye from 1 January 2026 and had neither domicile nor tax liability there in the three preceding calendar years, income you earn outside Türkiye — including income from the United States — is exempt in Türkiye for twenty years (repeated art. 20/D GVK). It is not declared in Türkiye. A U.S. citizen still pays full U.S. tax on it, with no Turkish tax to credit.
No U.S.–Türkiye social security (totalization) agreement. Türkiye is not on SSA's list of agreements in force, so paying both U.S. Social Security (or self-employment tax) and Turkish SGK contributions on the same work is not prevented by an agreement. Under Art. 18(2) of the tax Convention, however, social security payments made under one country's legislation — including payments to U.S. citizens — are taxable only in the paying country: a Turkish resident's U.S. Social Security benefits only in the United States, a U.S. resident's SGK pension only in Türkiye.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Government of the United States of America and the Government of the Republic of Turkey for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, and Protocol (signed at Washington on 28 March 1996). The tests are applied in order — permanent home, center of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities. U.S. citizens remain taxable in the United States under the saving clause.

Terms you will come across in Türkiye

Türkiye'de yerleşmiş: settled in Türkiye — domicile there or a continuous stay of more than six months in a calendar year
ikametgâh: domicile — the place where you live with the intention of remaining permanently
tam mükellefiyet: full tax liability on income earned in and outside Türkiye
dar mükellefiyet: limited tax liability on income earned in Türkiye only
mukimlik belgesi: certificate of tax residence issued by the Turkish tax office
yıllık beyanname: annual income tax return, filed in March of the following year

Questions

I am a U.S. citizen living in Türkiye — how is double taxation relieved?

The United States keeps taxing you as a citizen under the saving clause (Art. 1(3)); relief from double taxation (Art. 23) is one of the exceptions in Art. 1(4). As a Turkish resident you credit U.S. income tax against Turkish income tax up to the Turkish tax on that income (Art. 23(2); art. 123 GVK), proving the payment with documents from the U.S. authorities certified by a Turkish consulate. For U.S. tax charged only because of citizenship, Art. 23(3) sets special source and credit rules; on the U.S. side you use the foreign tax credit (Form 1116) or the foreign earned income exclusion (Form 2555).

I am moving to Türkiye — does the 20-year exemption for foreign income help a U.S. citizen?

If you become settled in Türkiye from 1 January 2026 and had neither domicile nor tax liability there in the three preceding calendar years, income you earn outside Türkiye — including income from the United States — is exempt in Türkiye for twenty years and is not declared there (repeated art. 20/D GVK). The United States still taxes a citizen in full on that income, and there is no Turkish tax to credit.

How long can I work in Türkiye for a U.S. employer before Türkiye taxes my salary?

If the United States is your treaty residence, Türkiye does not tax the pay for work done there only if you are present no more than 183 days in any continuous 12-month period, the employer is not resident in Türkiye, and the pay is not borne by a permanent establishment or fixed base of the employer in Türkiye (Art. 15(2)). Otherwise Türkiye taxes the pay for your Turkish work days and the United States credits the Turkish tax. There is no U.S.–Türkiye social security agreement, so contributions to both systems on the same work are not prevented.

Sources

Legislation and official guidance

GVK (Income Tax Law No. 193), art. 3 — Persons settled in Türkiye, and Turkish citizens living abroad who are attached to Turkish public offices or institutions or to organisations or enterprises headquartered in Türkiye and are abroad on their business, are taxed on all income earned in and outside Türkiye (full liability). Those in the second group are not taxed again on income that is subject to income tax or a similar tax in the country where they are.
General Communiqué on Income Tax No. 210 (Official Gazette 06.03.1998, No. 23278) — GİB Guide on Rental Income for Limited Taxpayers (February 2025, Publication No. 553) — Turkish citizens who have lived abroad for more than six months with a work or residence permit are taxed as limited (non-resident) taxpayers on their income from Türkiye; those abroad in the service of Turkish public bodies or of enterprises headquartered in Türkiye are excluded.
GİB ruling of the Balıkesir Tax Office Directorate, 19.09.2013, B.07.1.GİB.4.10.15.01-125[10-2013/849]-88 — Citing Communiqué No. 210: the domicile of Turkish citizens who have lived abroad for more than six months with a work or residence permit is accepted to be in the country where they live and they are taxed as limited taxpayers; those who return permanently or stay in Türkiye for more than six months in a calendar year are fully liable.
GVK, art. 4 — Settled in Türkiye are: 1) persons whose domicile is in Türkiye (domicile as defined in art. 19 et seq. of the Civil Code); 2) persons who stay in Türkiye continuously for more than six months in a calendar year — temporary departures do not interrupt the stay.
Turkish Civil Code (Law No. 4721), arts 19–20 — Domicile is the place where a person lives with the intention of remaining permanently; no one can have more than one domicile at a time. Domicile changes only when a new one is acquired; a person who has left a domicile abroad and not yet acquired one in Türkiye is domiciled where he or she currently lives.
GVK, art. 5 — Businessmen, scientists, experts, officials, press correspondents and similar persons who come for a definite and temporary assignment or job, foreigners who come for study, medical treatment, rest or travel, and persons who stay in Türkiye for reasons beyond their control such as detention, imprisonment or illness are not regarded as settled in Türkiye even if they stay longer than six months.
GVK, art. 6 — Individuals not settled in Türkiye are taxed only on income earned in Türkiye (limited liability).
GVK, art. 7/3-a and final paragraph — For limited taxpayers, salary is earned in Türkiye if the service is performed in Türkiye or is «evaluated» in Türkiye — i.e. paid in Türkiye or, if paid abroad, booked in the accounts of the payer in Türkiye (or of the person on whose behalf it is paid) or set off against its profit.
Art. 4(2) and Protocol para. 1 of the U.S.–Turkey Convention (1996)
Art. 1(3)–(4) of the U.S.–Turkey Convention (saving clause)
Art. 23 of the U.S.–Turkey Convention (relief from double taxation)
§ 7701(b)(3)(A); Treas. Reg. § 301.7701(b)-1(c)
Art. 15(2) of the U.S.–Turkey Convention
Treas. Reg. § 301.7701(b)-7; 26 U.S.C. § 6114
GVK, art. 123 — Foreign taxes of a similar nature paid abroad by fully liable taxpayers on income earned abroad are deducted from the Turkish income tax attributable to that income; any excess is disregarded. Conditions: a personal tax on income, and payment proved by documents from the competent authorities certified by the Turkish embassy or consulate there. If the documents arrive late, the tax on the foreign income is deferred for one year.
GVK, repeated art. 20/D (Law No. 7582, art. 4, Official Gazette 04.06.2026) — Income earned outside Türkiye by individuals who had neither domicile nor tax liability in Türkiye in the last three calendar years before becoming settled is exempt for twenty years; such income is not declared, related expenses are not deductible and foreign tax on it cannot be credited.
SSA — U.S. international social security agreements (status)
Art. 18(2) of the U.S.–Turkey Convention (social security payments)
GVK, art. 103; General Communiqué on Income Tax No. 332 (Official Gazette 31.12.2025, No. 33124, 5th repeat) — 2026 tariff: up to TRY 190,000 — 15%; up to TRY 400,000 — 20%; up to TRY 1,000,000 (salaries TRY 1,500,000) — 27%; up to TRY 5,300,000 — 35%; above — 40%.
GVK, art. 86 — Fully liable taxpayers need not file an annual return for salary from a single employer taxed by withholding up to the fourth bracket amount. Limited taxpayers need not file for salary, professional fees, income from movable and immovable capital and other income fully taxed by withholding in Türkiye.
GVK, art. 92 — The annual return is filed in March of the following year (extended to the last day of March by VUK Circular No. 115) with the competent tax office; persons leaving the country during the year file within 15 days before departure.
GVK, art. 23/13 and 23/19 — Retirement, disability, widow's and orphan's pensions paid by foreign social security institutions are exempt; so are wages paid out of foreign profits to persons employed abroad in construction, repair, installation and technical services.
Art. 4(2)(a) of the U.S.–Turkey Convention (1996) — An individual is deemed a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he is deemed a resident only of the State with which his personal and economic relations are closer (centre of vital interests).
Protocol, para. 1 (ad Art. 4) — Whether a national of a Contracting State is a resident of the United States, of Türkiye or of a third State is determined under the principles of Art. 4(2)(a)–(d).
Art. 4(2)(b) of the U.S.–Turkey Convention (1996) — If the State in which he has his centre of vital interests cannot be determined, or if he does not have a permanent home available to him in either State, he is deemed a resident only of the State in which he has an habitual abode.
Art. 4(2)(c)–(d) of the U.S.–Turkey Convention (1996) — If he has an habitual abode in both States or in neither, he is deemed a resident only of the State of which he is a national (c); if he is a national of both States or of neither, the competent authorities settle the question by mutual agreement (d).

Case law

Council of State (Danıştay), 4th Chamber, E. 2021/8176, K. 2022/8419, 2022-12-19 — In a VAT case (art. 13/i VAT Law — sale of dwellings to foreigners) the Chamber assessed the condition «not settled in Türkiye» under arts 4 and 5 GVK: the condition must be met on the date of the sale; a certificate from the tax office that the buyer is not settled is only evidence, and obtaining it after the sale does not bar the exemption for a buyer who proves the conditions. The decision concerns VAT but applies the income tax settlement criteria.

Updated 2026-11-04. The result is for information only and is not tax or legal advice. Tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes. Consult a qualified adviser before making decisions.

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