How to Prove the USD 400,000 Property Value for Turkish Citizenship
Contents
- The USD 400,000 legal threshold
- Why the private contract price is not enough
- The official deed or preliminary sale contract
- Bank payment evidence
- Foreign Currency Purchase Certificate (DAB)
- TTB and current value assessment
- Multiple properties and aggregation
- Mortgage, credit and net qualifying amount
- Pre-closing legal audit
- Common documentary failures
- Frequently asked questions
1. The USD 400,000 legal threshold
Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law sets the real-estate investment route used for exceptional citizenship under Article 12 of Turkish Citizenship Law No. 5901. The current official threshold is at least USD 400,000 or the qualifying foreign-currency equivalent. The property must also be subject to the citizenship-specific three-year restriction recorded in the land registry, or, for an eligible notarised preliminary sale contract, the legally required three-year restriction against transfer and cancellation must be registered.
The threshold is a legal eligibility requirement. It is not satisfied simply because a seller advertises a property at USD 400,000, because an estate agent states that the property is “citizenship suitable,” or because the parties insert that figure into a private reservation agreement. The official file must establish the qualifying amount using the records required by the land-registry administration.
The starting point for the complete investment structure is our guide on which authority issues the conformity certificate for Turkish citizenship by investment.
2. Why the private contract price is not enough
A private purchase agreement can regulate contractual rights between buyer and seller, but citizenship eligibility is assessed through public records. The land registry and the citizenship conformity process examine the transaction through the official instrument, payment evidence and the citizenship-specific value determination mechanism. If those records do not meet the required amount, a side letter or an estate-agent invoice cannot repair the citizenship file.
Foreign investors should therefore separate three questions: what the parties agreed commercially; what was declared in the official title or eligible preliminary sale transaction; and what amount is accepted for the citizenship calculation. A legally safe closing must make those components consistent before the buyer transfers the final funds or signs the title deed.
Under the current TKGM guidance, the required amount is tested through the official documentation and the current Taşınmaz Edinim Sureti ile Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi (TTB) workflow. This makes pre-closing verification more important than a post-closing attempt to reconstruct the file.
3. The official deed or preliminary sale contract
For a completed sale, the title-deed transaction must contain the official sale consideration. For an eligible notarised preliminary sale contract, the contract must satisfy the citizenship rules applicable to that route, including the property-status requirements and the payment timing requirements. The 2024 TKGM guidance states that the qualifying amount must be met in the relevant official sale or preliminary-sale records and confirmed within the citizenship amount assessment.
The real-estate route no longer covers every type of undeveloped land without distinction. The Regulation was amended in December 2023 so that the citizenship property route focuses on property with condominium ownership or condominium easement, or land on which a building exists, subject to the detailed TKGM rules. A buyer who is also subject to the general foreign-acquisition rules under Article 35 of Land Registry Law No. 2644 must satisfy those rules separately.
For the foreign ownership framework, see Buying Property in Turkey for Foreigners: Article 35.
4. Bank payment evidence
The payment trail is a separate evidentiary element. The buyer should use a banking channel that produces records identifying the sender, recipient, amount, currency, date and transaction reference. The records should connect the payment to the specific real-estate transaction. Cash payments create an obvious evidence problem for a citizenship file because the administrative process requires traceable documentation rather than an unverifiable statement that funds changed hands.
The TKGM guidance requires the transfer/payment totals used for citizenship to reach the statutory amount independently of the amount appearing in the official deed or qualifying preliminary sale contract. In other words, a title deed showing a sufficient figure does not cure an insufficient documented payment trail. The inverse is also true: sending a large sum does not cure an official deed or contract that fails the applicable amount test.
Foreign investors should also preserve SWIFT records, bank receipts and account statements in a form that can be matched to the buyer and seller. If funds are sent by an authorised representative, spouse, company or other third party, the legal acceptability of that structure should be checked before transfer rather than assumed afterward. The dedicated cross-border payment guide is at Cross-Border Transfer for Citizenship Property: SWIFT, Sender Identity and Payment Trace.
5. Foreign Currency Purchase Certificate (DAB)
Since 24 January 2022, foreign natural persons purchasing real estate in Turkey are subject to the foreign-currency sale procedure described by the Central Bank and TKGM. The foreign currency used for the acquisition is sold through a bank to the Central Bank, and the bank issues the Döviz Alım Belgesi, commonly called the Foreign Currency Purchase Certificate or DAB, for the title-deed file.
The DAB is not merely an optional bank document for citizenship applicants. TKGM’s official announcement states that foreign natural-person acquisition transactions require the foreign currency to be sold through a bank to the Central Bank and the resulting DAB to be submitted to the land registry. The amount shown in the DAB is integrated into the official transaction record under the applicable rules.
Because the DAB interacts with the payment and title-deed figures, the bank instruction should be coordinated with the closing documents. Our detailed article is Foreign Currency Purchase Certificate for Citizenship Property: Bank Payment and FX Evidence.
6. TTB and the current citizenship amount assessment
Foreign-buyer valuation practice has evolved. Investors should not rely on old internet articles that describe every citizenship file solely through a generic “appraisal report.” TKGM’s current materials refer to the citizenship-specific Taşınmaz Edinim Sureti ile Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi (TTB), prepared within the current valuation/assessment system in accordance with the 2024/4 framework.
The official TTB example states that the document is prepared through the TADEBİS system as part of the citizenship amount determination. TKGM’s current FAQ also explains the treatment of files where the valuation result does not meet USD 400,000 and distinguishes older reports from TTB documents issued after 9 December 2024. For a current transaction, the decisive practical point is to obtain and review the citizenship-specific amount determination applicable on the filing date.
The buyer should therefore insist on seeing the official value evidence before the closing becomes irreversible. A private valuation commissioned by the buyer for commercial due diligence can still be useful, but it is not the same legal object as the citizenship amount document used by the administration.
7. Multiple properties and aggregation
TKGM guidance permits more than one property to be used in a purchase-based citizenship file, provided the applicable aggregate amount and documentation rules are satisfied. Each property must be eligible, and the combined official purchase/payment evidence must meet the required threshold. A weak property in a multi-property package does not become compliant merely because the aggregate commercial package price exceeds USD 400,000.
For preliminary sale contracts, the rules are more specific: the qualifying amount must be satisfied under the eligible contract structure, and current TKGM guidance requires the properties included in the promise to be identified within the same qualifying contract. Mixing completed acquisitions and preliminary sale promises simply to fill a shortfall is restricted under the guidance and should not be improvised at closing.
Because multi-property transactions create more documents, they also create more opportunities for mismatch between title data, bank payment references, DAB records and TTB values. A reconciliation table prepared before filing is a practical legal-control tool.
8. Mortgage, credit and the net qualifying amount
Encumbrances do not all have the same legal effect. A property may be purchased subject to a mortgage or financing arrangement, but the citizenship calculation must be reviewed under the TKGM rules applicable to the transaction. The current TKGM guide explains that where a property is purchased using foreign-currency credit, the credit amount is deducted when determining whether the required investment amount is met.
This rule is important because an investor can pay a headline price above USD 400,000 while the citizenship-eligible net amount falls below the threshold after the relevant deduction. The safe approach is to calculate the citizenship amount using the official method before signing financing documents.
For a wider encumbrance review, see Land Registry Due Diligence for Citizenship Property: Mortgages, Seizures and Zoning.
9. Pre-closing legal audit
A citizenship property should be audited before the irrevocable payment and title transfer. The review should identify the registered owner, property type, condominium or building status, mortgages, attachments, usufructs, court annotations, development/zoning issues, foreign-acquisition restrictions, seller-side citizenship restrictions, prior use of the property for a citizenship file, and the exact payment mechanics.
The audit should then reconcile the expected deed amount, bank transfer plan, DAB amount and citizenship TTB result. If the transaction uses a preliminary sale contract, the notarial form, eligibility of the property, full payment timing and land-registry annotation must be checked against the current guide.
This document-first method protects both citizenship eligibility and the underlying acquisition. A buyer should never sacrifice ordinary title safety merely because a property is marketed as “approved for citizenship.”
10. Common documentary failures
Common failures include using a private contract amount that is higher than the official title amount; paying part of the consideration in cash; sending funds from an unrelated third party without prior legal analysis; obtaining the DAB for a figure that does not reconcile with the closing documents; relying on an outdated appraisal rule; acquiring an ineligible share instead of the whole qualifying property; and discovering only after payment that the property or seller falls within a restriction in the current TKGM guide.
A second recurring problem is timing. Documents prepared after the transaction may not retroactively satisfy a rule that had to be met at the moment of payment, notarisation, title transfer or registration of the three-year restriction. Citizenship planning must therefore be integrated into the closing process from the beginning.
Frequently Asked Questions
Is a USD 400,000 private sales contract enough?
No. Citizenship eligibility is assessed through the official land-registry and payment documentation required by the current TKGM process.
Must both the official price and payment records reach USD 400,000?
The current TKGM guide requires the official transaction amount and documented transfer/payment totals used in the citizenship calculation to satisfy the applicable minimum and to be confirmed through the citizenship amount-determination process.
What is a TTB?
TTB is the current citizenship-specific amount determination document used within the TKGM valuation framework for property-based citizenship files.
Is a DAB required when a foreigner buys property?
Yes. TKGM states that foreign natural-person purchases are subject to the Central Bank foreign-currency sale procedure and the DAB must be submitted in the title-deed process.
Can several properties be combined?
Purchase-based applications can use more than one eligible property if the current aggregate amount and documentation rules are met.
Can several foreigners buy shares in one property and each apply?
No for acquisitions made under the current TKGM guidance. Since the 1 February 2023 guide, acquisition of a fractional share for this citizenship route is not accepted as a qualifying new acquisition.
Can a mortgage reduce the citizenship value?
Yes, the treatment depends on the encumbrance and financing structure. TKGM specifically provides for deduction of relevant foreign-currency credit when determining the qualifying amount.
Can I pay in cash and later obtain a receipt?
A citizenship file requires the documented payment trail contemplated by the official guidance. A later private receipt is not a substitute for the required banking evidence.
Does a property worth USD 400,000 automatically guarantee citizenship?
No. The property route is only one eligibility condition for exceptional citizenship. The conformity and citizenship decisions remain separate administrative stages.
When should the legal review be completed?
Before the final funds are transferred and before the title deed or preliminary sale contract becomes legally binding for citizenship purposes.
Official legal sources
- NVI – Citizenship Services FAQ
- TKGM – Regulation amendment and property route
- TKGM – Valuation reports and current guidance
- TKGM – Foreign Currency Purchase Certificate announcement
- Turkish Citizenship Law No. 5901
- Land Registry Law No. 2644
Reviewed for the 2026 Turkish citizenship and land-registry framework by Av. Halil Bakırcı, Mersin Bar Association, Registration No. 3472. This article is for international investors who require a document-based legal review before transferring funds or acquiring property in Turkey.
For English-language legal assistance from abroad, see Legal Services in Turkey for International Clients.
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