USD 400,000 Threshold: Purchase Price, FX Conversion and Title-Deed Evidence
The USD 400,000 threshold must be supported by consistent official price, payment and currency records.
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Contents
- The legal threshold and why exchange-rate timing matters
- Official sale price versus commercial price
- Payment records as an independent test
- DAB and Central Bank conversion mechanics
- Which date controls the USD comparison
- Installments and historic payments
- Preliminary sale contracts
- Why leaving a small margin is legally prudent
- Closing reconciliation checklist
- Frequently asked questions
1. The legal threshold and why exchange-rate timing matters
The real-estate route under Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law requires an eligible acquisition with a qualifying amount of at least USD 400,000. Article 12 of Law No. 5901 supplies the statutory framework for exceptional citizenship. The land-registry rules determine how the investment condition is documented and verified.
The threshold is expressed in United States dollars. A transaction, however, can involve Turkish lira records, foreign-currency transfers, a DAB and a title-deed consideration. That creates a legal question that ordinary property buyers do not always face: which official exchange-rate mechanism is used to test the threshold?
TKGM guidance provides the answer through transaction-specific rules. The citizenship file is not based on a buyer selecting the most favorable exchange rate after closing. The relevant records and conversion method are tied to the applicable payment and DAB framework. This is why a transaction that appears comfortably above USD 400,000 in a marketing brochure can become borderline when official figures are reconciled.
2. Official sale price versus commercial price
The parties may negotiate a total commercial package containing furniture, management services, rental guarantees, taxes, commissions or other items. Those amounts should not automatically be treated as citizenship-eligible real-estate consideration. Citizenship is linked to the qualifying property acquisition and the amount accepted within the official TKGM process.
The official title-deed instrument or qualifying preliminary sale contract therefore has central importance. The amount recorded there must satisfy the rules applicable to the citizenship route. A private invoice for furniture or a consultancy fee does not increase the qualifying title value merely because the buyer pays it to the same seller group.
A legal review should separate the property consideration from ancillary items before the contract is signed. If the investor needs USD 400,000 of qualifying property value, the file should not depend on counting a non-property charge toward the statutory minimum.
3. Payment records are an independent evidentiary test
TKGM’s current guide treats documented payment/transfers as a separate part of the amount analysis. The transfer records should identify the buyer or authorised payer, the seller or authorised recipient, the date, amount and banking reference. The total used in the citizenship calculation must meet the minimum under the current rules.
This means an official title amount above USD 400,000 is not enough if the documented payment trail supports a lower amount. Likewise, a large bank transfer does not cure an official transaction record that fails the applicable amount test. Both sides of the evidence should be reconciled.
International clients should retain SWIFT confirmations in addition to local bank receipts. The SWIFT message can be decisive where funds originate abroad, because it helps establish the source account, beneficiary, currency and transfer date. Our dedicated guide on this point is Bank payment evidence and cross-border transfer records.
4. DAB and Central Bank conversion mechanics
For foreign natural-person real-estate acquisitions, TKGM’s official announcement states that the buyer’s foreign currency is sold through a bank to the Central Bank under the applicable capital-movements and implementation instructions. The bank then issues the Foreign Currency Purchase Certificate, known as the DAB, which is presented in the land-registry process.
The DAB is therefore part of the official currency and payment architecture. The buyer should not first agree an informal conversion with the seller and only later ask the bank to create documents that approximate the deal. The bank instructions, DAB amount, transfer trail and title-deed record should be planned as one closing sequence.
For a detailed explanation, see Foreign Currency Purchase Certificate (DAB): the payment-evidence guide.
5. Which date controls the USD comparison?
The answer depends on the payment and document chronology governed by the TKGM guide. Historical payments made before the DAB system began on 24 January 2022 are treated differently from later payments. The 2024 TKGM citizenship guide explains that qualifying older payments are converted using the Central Bank effective selling rate or cross rates of the business day preceding the payment date. Post-DAB payments are evaluated within the newer DAB framework.
This distinction is critical in installment transactions. An investor cannot safely convert the entire historical Turkish-lira payment total at today’s rate. Each payment may have to be assessed under the rule that applied on its date. A legal file therefore needs a payment chronology, not just one total number.
For new 2026 acquisitions the practical solution is simpler: design the payment and DAB sequence under the current rules from the beginning and obtain the official records before title transfer.
6. Installments and historic payments
Installment sales require careful separation of payment dates. TKGM guidance contains transitional rules for payments made before the DAB regime. For later installments, the current foreign-currency sale and documentary rules apply. The official sale amount must also correspond to the accepted payment/DAB structure under the guide.
A spreadsheet prepared by the buyer or developer is useful internally but does not replace bank records. Each installment should be supported by an identifiable transfer. If a payment description does not identify the project, unit or contract, a lawyer should obtain the additional documentary link before the citizenship conformity file is submitted.
Where a transaction spans a major regulatory change, the file should be analyzed under the rule in force at each relevant date rather than under a single modern rule applied retroactively.
7. Preliminary sale contracts have their own amount rules
A notarised preliminary sale contract can qualify only where the property and contract satisfy the current citizenship framework. The Regulation and TKGM guide impose specific requirements concerning property status, payment and the three-year restriction against transfer/cancellation of the promise.
The USD 400,000 amount must be paid in accordance with the rule applicable to the preliminary-sale route. Current TKGM guidance requires the qualifying amount to be paid by the relevant contract date and evidenced. A promise to pay the balance later should not be treated as equivalent to a fully qualifying citizenship payment.
The off-plan structure is discussed separately in Notarised Promise to Sell: Property Citizenship Requirements.
8. Why a small exchange-rate margin can create a large legal risk
The legal minimum is exactly USD 400,000, but building a transaction with no numerical margin is commercially risky. Exchange-rate movement, excluded charges, a financing deduction or a document mismatch can push the accepted amount below the statutory floor. The law does not contain a doctrine that rounds up a shortfall because the buyer was “close enough.”
That does not mean a lawyer should invent a higher legal threshold. The statutory figure remains USD 400,000. It means the transaction should be structured so the official qualifying records clearly exceed the threshold rather than relying on a disputed last-dollar calculation.
This is a risk-control point, not a change in the law. The exact official amount should always be confirmed from the documents before title transfer.
9. Closing reconciliation checklist
Before title transfer, the legal file should answer nine questions: Is the property itself eligible? Is the seller eligible under current TKGM restrictions? Does the official transaction amount meet the threshold? Do documented transfers independently meet the threshold? Is the DAB correctly issued? Does the current TTB/citizenship amount determination support the file? Are any credit deductions relevant? Is the three-year restriction ready to be registered? Do the buyer’s identity and civil-status documents match the citizenship file?
That reconciliation should be completed before the final appointment. After registration, correcting an amount or a payment trail can be legally impossible if the relevant requirement had to exist at the moment of transfer.
For the value-evidence framework, read How to Prove the USD 400,000 Property Value for Turkish Citizenship. For the general workflow, see Citizenship-by-Investment Conformity Certificate Authorities.
10. Common mistakes in threshold calculations
The most frequent errors are counting furniture or service charges as qualifying property price; using a private exchange rate; assuming the deed amount alone is sufficient; assuming the bank transfer alone is sufficient; failing to reconcile the DAB; applying today’s exchange rate to old installments; ignoring a financing deduction; and leaving the transaction exactly at the threshold without confirming the official amount determination.
Another error is to rely on an outdated blog post. TKGM has changed the valuation and amount-assessment system, including the 2024/4 framework and the TTB process. A 2026 transaction should be checked against the current official guide and forms.
Frequently Asked Questions
Is USD 400,000 still the property threshold in 2026?
Yes. Current NVI and TKGM materials state a minimum of USD 400,000 for the qualifying real-estate route.
Can furniture be counted toward the threshold?
The citizenship route concerns the qualifying real-estate acquisition. Ancillary goods or service charges should not be assumed to increase the qualifying property amount.
Can the parties choose their own USD exchange rate?
No. The citizenship calculation follows the official rules applicable to the transaction and payment dates.
Does the title deed price alone prove the threshold?
No. The payment evidence and current citizenship amount-determination process must also support the file.
Does a bank transfer above USD 400,000 solve a low title amount?
No. The official transaction amount and payment trail are separate components and must be consistent with the applicable rules.
What is the DAB date?
The foreign-buyer DAB regime applies from 24 January 2022 under the official TKGM announcement and related Central Bank instructions.
How are older payments converted?
TKGM guidance provides transitional conversion rules, including use of the preceding business day’s Central Bank effective selling or cross rate for qualifying pre-DAB payments.
Can I pay the balance after signing a citizenship preliminary sale contract?
The qualifying preliminary-sale route has specific payment timing requirements. Current TKGM guidance requires the statutory amount to be paid within the legally prescribed timing for that contract structure.
Should the purchase be exactly USD 400,000?
The legal minimum is USD 400,000. A transaction should nevertheless be structured so official qualifying records do not fall below the threshold because of an excluded item, financing deduction or conversion issue.
Who verifies the final property investment condition?
The competent land-registry/cadastre authority verifies the real-estate investment condition within the framework established under Article 20 of the Citizenship Regulation.
Official legal sources
- NVI – Citizenship Services FAQ
- TKGM – Citizenship Regulation amendment
- TKGM – DAB announcement for foreign buyers
- TKGM – Valuation and amount assessment materials
Reviewed for the 2026 Turkish citizenship and land-registry framework by Av. Halil Bakırcı, Mersin Bar Association, Registration No. 3472. The purpose is to give international investors a transaction-level explanation of the official USD threshold and currency evidence before funds are committed.
For English-language representation from abroad, visit Legal Services in Turkey for International Clients.
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