Tax residence in Türkiye for Pakistani taxpayers

Türkiye treats you as settled, and fully liable on worldwide income, if your domicile is in Türkiye or you stay there continuously for more than six months in a calendar year; foreigners who come for a definite and temporary assignment or job, study, medical treatment, rest or travel are not settled even after six months. Pakistan counts its own tax year of 1 July – 30 June, and a Pakistani citizen can stay resident under s. 82(d) with fewer than 183 days. Where both countries claim you, Art. 4(2) of the 1985 Pakistan–Türkiye Agreement decides: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement.

Check your status: Pakistan and Türkiye

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, 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 Pakistani tax rules

Collision: Pakistani citizen settled in Türkiye. Under s. 82(d) a Pakistani citizen stays resident in Pakistan unless present in another country for more than 182 days in the Pakistani tax year or treated as a resident taxpayer there. If Türkiye treats you as fully liable (domicile in Türkiye, or more than six months there in a calendar year), a Turkish certificate of residence shows the second condition. If both countries still treat you as resident, Art. 4(2) of the 1985 Agreement decides: permanent home → centre of vital interests → habitual abode → nationality → mutual agreement.
Collision: domicile keeps you settled in Türkiye while Pakistan also treats you as 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 Pakistan also treats you as resident (183 days in its tax year, a government posting under s. 82(c), or citizenship under s. 82(d)), Art. 4(2) of the Pakistan–Türkiye Agreement decides which country is your state of residence.
Collision: more than six months in Türkiye while resident in Pakistan. A continuous stay of more than six months in a calendar year makes you settled in Türkiye. Because the Pakistani tax year runs from 1 July, the same period can fall in a Pakistani tax year in which you are also resident — typically in the year of a move. Art. 4(2) of the Pakistan–Türkiye Agreement then decides; ask the Turkish tax office for a certificate of residence if Türkiye is your state of residence.

What else to know

Different tax years: 1 July in Pakistan, the calendar year in Türkiye. Pakistan counts days in its tax year (1 July – 30 June); Türkiye's six-month test looks at a continuous stay of more than six months within a 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) of the Pakistan–Türkiye Agreement is counted in the calendar year concerned.
Turkish citizen living in Pakistan 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.
Working in Türkiye while resident in Pakistan (Art. 15(2)). Pay for work physically done in Türkiye is Turkish-source income. If Pakistan is your treaty residence, Türkiye does not tax it only if all three conditions of Art. 15(2) are met: not more than 183 days in Türkiye in the calendar year concerned, an employer that is not resident in Türkiye, and pay not borne by a permanent establishment or fixed base of the employer in Türkiye. In Pakistan, salary earned abroad is exempt if Turkish tax on it was withheld and paid to the Turkish tax authority (s. 102).
How double tax is relieved between Pakistan and Türkiye. If you are resident in Pakistan, foreign salary taxed and withheld in Türkiye is exempt (s. 102); for other Turkish income Pakistan gives a credit for Turkish tax, limited per head of income to the Pakistani tax on that income, with no carry-forward (s. 103; s. 107 gives the treaty priority). If you are resident in Türkiye, Türkiye credits the Pakistani tax against Turkish tax on that income (Art. 22(3); art. 123 GVK), with payment proved by documents certified by the Turkish embassy or consulate in Pakistan.
Pakistani government posting to Türkiye. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c), whatever their days in Türkiye. Whether Türkiye may tax their government salary depends on the government service article of the 1985 Agreement and on diplomatic status; that article was not analysed here.
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 Pakistan — is exempt in Türkiye for twenty years (repeated art. 20/D GVK). It is not declared, and Pakistani tax on it cannot be credited in Türkiye. A Pakistani citizen who leaves Pakistan during the tax year and stays abroad for the rest of it is exempt in Pakistan on salary earned abroad in that year (s. 51(2)).
Which treaty applies: the 1985 Pakistan–Türkiye Agreement. The Agreement signed at Islamabad on 14 November 1985 applies; it entered into force on 8 August 1988. Residence: Art. 4(2) — permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement; employment: Art. 15 (183 days in the calendar year); relief: Art. 22 (Türkiye credit); mutual agreement: Art. 25. Social security contributions are outside the treaty — check with SGK and your employer before a posting.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Agreement between the Islamic Republic of Pakistan and the Republic of Turkey for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Islamabad on 14 November 1985). The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

Terms you will come across in Türkiye

ikametgâh: domicile — the place where you live with the intention of remaining permanently (Turkish Civil Code, arts 19–20)
Türkiye'de yerleşmiş: settled in Türkiye — domicile there or a continuous stay of more than six months in a calendar year (art. 4 GVK)
tam mükellefiyet: full tax liability on all income earned in and outside Türkiye (art. 3 GVK)
dar mükellefiyet: limited tax liability on income earned in Türkiye only (art. 6 GVK)
mukimlik belgesi: Turkish certificate of residence, issued by the tax office; it can show you are a resident taxpayer there for s. 82(d)
yıllık beyanname: annual income tax return, filed in March of the following year (art. 92 GVK)

Questions

Which tax treaty applies between Pakistan and Türkiye?

The Agreement signed at Islamabad on 14 November 1985, in force since 8 August 1988; it applies in Pakistan from 1 July 1989. Its tie-breaker for individuals is Art. 4(2), salaries fall under Art. 15 (183 days in the calendar year concerned), and mutual agreement cases under Art. 25.

I am a Pakistani citizen working in Türkiye — am I still resident in Pakistan?

Under s. 82(d) a citizen stays resident unless present in another country for more than 182 days in the Pakistani tax year or treated as a resident taxpayer there; a Turkish certificate of residence shows the second condition. If both countries still treat you as resident, Art. 4(2) of the 1985 Agreement decides.

How is double tax relieved between Pakistan and Türkiye?

If you are resident in Pakistan, salary taxed and withheld in Türkiye is exempt (s. 102), and Pakistan credits Turkish tax on other income up to the Pakistani tax on it, per head of income and with no carry-forward (s. 103). If you are resident in Türkiye, Türkiye credits Pakistani tax against Turkish tax on that income (Art. 22(3); art. 123 GVK).

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.
Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Art. 15(2) Pakistan–Türkiye Agreement (1985) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the first State if the recipient is present in the other State for not more than 183 days in aggregate in the calendar year concerned, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer there.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; consolidated text amended up to 30.06.2026 listed by FBR) — A citizen of Pakistan is also a resident individual if he or she is not present in any other country for more than 182 days during the tax year, or is not a resident taxpayer of any other country. Applies from tax year 2023.
Art. 4(2) Pakistan–Türkiye Agreement (1985) — Individual resident of both States: (a) resident of the State in which he has a permanent home; with a permanent home in both, of the State with which his personal and economic relations are closer (centre of vital interests); (b) if that State cannot be determined, or he has no permanent home in either State, of the State of habitual abode; (c) habitual abode in both or neither — the State of which he is a national; (d) national of both or neither — mutual agreement.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income, computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
Income Tax Ordinance, 2001, s. 107(2) — Subject to s. 109, a double taxation agreement and its implementing notification have effect notwithstanding anything in any other law, so far as they provide relief from tax under the Ordinance or determine the Pakistan-source income of non-residents.
Art. 22(3) Pakistan–Türkiye Agreement (1985) — Türkiye allows the tax paid in Pakistan on income that may be taxed in Pakistan under the Agreement as a credit against the Turkish tax on that income, subject to Turkish law.
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.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
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.
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
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) Pakistan–Türkiye Agreement (1985) — Resident 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, resident of the State with which his personal and economic relations are closer (centre of vital interests).
Art. 4(2)(b) Pakistan–Türkiye Agreement (1985) — If the centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, the individual is deemed a resident of the State in which he has an habitual abode.
Art. 4(2)(c) Pakistan–Türkiye Agreement (1985) — If he has an habitual abode in both Contracting States or in neither of them, he is deemed a resident of the Contracting State of which he is a national.
Art. 4(2)(d) Pakistan–Türkiye Agreement (1985) — If he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States settle the question by mutual agreement.
Art. 25 Pakistan–Türkiye Agreement (1985) (mutual agreement procedure) — A person who considers that the actions of one or both States result in taxation not in accordance with the Agreement may present the case to the competent authority of the State of which he is a resident; the competent authorities endeavour to resolve the case by mutual agreement.

Case law

Council of State (Danıştay), 4th Chamber, E. 2021/8176, K. 2022/8419, 19/12/2022 — 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 04/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

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