1. Legal Framework: Citizenship by Investment Through Real Estate in Turkey
Turkish citizenship by investment through property acquisition is mainly governed by:
- Turkish Citizenship Law No. 5901, and
- The Regulation on the Implementation of the Turkish Citizenship Law, together with various circulars and internal guidelines of the Ministry of Interior and the General Directorate of Land Registry and Cadastre (Tapu ve Kadastro Genel Müdürlüğü, TKGM).
Under the current rules (subject to changes by the Presidency and the Ministry):
- A foreign investor can apply for Turkish citizenship by investment by purchasing real estate in Turkey with a minimum total value of USD 400,000 (or equivalent in Turkish lira at the date of transaction).
- The property must be:
- Registered in the name of the foreign investor in the land registry (tapu),
- Free from certain types of encumbrances (mortgages, seizure, etc. – with some exceptions),
- Accompanied by an official valuation report confirming that the market value meets or exceeds the required threshold, and
- Subject to a three-year restriction not to be sold, transferred, or otherwise disposed of (annotated on the title deed).
Within this regime, the State aims to attract genuine, long-term foreign capital rather than short-term speculative or “paper” transactions. That is why there are strict rules to prevent the same property being recycled for multiple citizenship applications.
2. Core Rule: A Single Property Cannot Be Used for Multiple Citizenship Applications
One of the key principles of the current system is:
A property that has been used once as the legal basis for Turkish citizenship by investment cannot be used again for another citizenship application.
This prohibition is reflected in:
- The Regulation on the Implementation of the Turkish Citizenship Law, and
- Administrative practice of the Ministry of Environment, Urbanization and Climate Change and the Ministry of Interior.
2.1 Why does this rule exist?
The logic is straightforward:
- Prevent “multiplying” citizenship out of a single asset
Without this restriction, one high-value apartment could theoretically be resold multiple times in a short period, with each buyer obtaining citizenship based on the same “economic contribution”. This would undermine the integrity and credibility of the program. - Avoid artificial inflation of values
The program already struggles with concerns about artificially inflated valuation reports. Allowing the same property to be used for multiple families would create additional, serious risks of abuse. - Ensure that every applicant brings “fresh” value to the Turkish economy
The idea is that every investor or family obtaining citizenship should make its own, distinct investment, not simply “reuse” an old one that already served as the basis for someone else’s citizenship.
3. How “Same Property” Is Understood in Practice
The practical question is: What exactly is considered the same property?
In Turkish legal and land registry practice, several concepts are important:
- Parcel (parsel): The land plot.
- Independent section (bağımsız bölüm): An apartment, shop, office etc. within a building, registered under a separate block/lot/independent unit number.
- Co-ownership or shares (hisse): Each co-owner holds an undivided share of the property (e.g. ½, ¼ etc.).
3.1 One independent section = one property
If we speak about a single apartment in a building (with its own independent section number), that apartment is considered one property for citizenship purposes.
Once it has been used for citizenship:
- It cannot be used again,
- Neither by the same investor for another application,
- Nor by the investor’s family members separately,
- Nor by a completely unrelated buyer later.
The title deed will reflect that this property was already the basis of a citizenship transaction, and the authorities will reject any new attempt to use it.
3.2 Shared ownership: Can each co-owner apply separately?
Sometimes, investors consider buying a property in shares (e.g. 60% – 40% among two foreigners) and wonder if:
- each co-owner can file a separate citizenship application using their share of the same property, or
- one co-owner applies now and the other later, using the same property again.
In practice, the answer is no if the intention is to treat that single property as a repetitive basis for multiple families. The authorities assess:
- Whether the investment structure is designed to circumvent the rule that one property cannot generate multiple citizenships,
- Whether the same asset is being reused, even through creative share arrangements.
The Ministry and land registry offices increasingly interpret the rules strictly, and tend to refuse structures that aim to generate multiple citizenships from the same property or the same set of properties.
4. One Household, One Investment: Family Applications on the Same Property
A common and legitimate practice is:
One main applicant purchases qualifying real estate, and the same investment is used to apply for citizenship for the applicant’s spouse and minor children as a single “family application”.
This is fully accepted and expected under Turkish law.
However, this family structure has important limits:
- The main investor is the one who acquires the property in their name.
- The spouse and children are included in the same citizenship file as dependents, as long as they meet the legal definition of family (marriage, minor or dependent kids, etc.).
- This does not mean that the same property can later be reused for another, separate family or for adult children once they marry and establish their own household.
In other words, a property can support one citizenship package for one “nuclear family” at a time, and that is the end of its use for citizenship purposes.
5. Risks When the Same Property Is “Recycled” or “Shared” Between Families
Despite the clear rules, the market sometimes sees aggressive sales tactics and dangerous structures designed around the same property. Typical risky scenarios include:
5.1 Developer promises: “We can use this flat for two citizenship applications”
Some developers or brokers may claim:
- “We can use this luxury flat for your family now and then for your relative’s family later.”
- “We will transfer the shares cleverly, and both of you will get citizenship.”
- “The rules are flexible, everyone does it.”
Such proposals are extremely risky. Once the property is used as the basis of a citizenship application:
- The land registry records will show this,
- The Ministry will see prior use from their internal systems,
- A second attempt to use the same property is likely to be detected and rejected.
The worst-case scenario is not just rejection, but potential allegations of abuse or misrepresentation, especially if artificial valuation or circular sale patterns are involved.
5.2 Circular transactions: Selling back and forth between related parties
Another risky pattern is when:
- A property is sold to Investor A, A obtains citizenship,
- Then the same property is sold to Investor B (a relative, friend or associate),
- Investor B attempts to use the same apartment as the investment basis for another citizenship file.
The authorities increasingly monitor:
- The transaction history of properties,
- Links between buyers and sellers (related parties, same group, same brokers),
- Patterns of repeated sales in a short period.
If the property has already been used for citizenship, it will simply not qualify again, regardless of who buys it.
5.3 Fractional valuation tricks: “We will show higher value each time”
Some “advisors” claim that because valuation reports can vary, it is possible to:
- “Upgrade” the value of the same apartment for a second application,
- Combine it with minor cosmetic improvements to justify a new report,
- Argue that the “new investment” is different from the old one.
Again, the core principle is:
Once a property enters the system as a citizenship-qualifying investment, its role is locked.
Trying to reintroduce the same asset through creative valuation does not change the fact that it is the same property with the same independent section number and parcel identity.
6. How the Authorities Technically Prevent Re-Use of the Same Property
The Turkish authorities use several technical and administrative tools to enforce the rule that the same property cannot support multiple citizenship applications.
6.1 Annotation on title deed (tapuya şerh)
When a property is used for a citizenship application:
- A restriction / annotation is placed on the title deed stating that the property cannot be sold or transferred for three years (typical rule for citizenship by investment).
- Information about the citizenship process is also connected to the land registry records.
Even after the three-year sale restriction expires, the authorities are still able to see that:
- The property served as the basis of a previous citizenship file, and
- It is therefore not eligible to serve again as a citizenship investment.
6.2 Centralized database and internal checks
Before issuing the Certificate of Conformity (Uygunluk Belgesi) which confirms that a property meets the citizenship criteria, the Ministry and land registry offices:
- Check the investment history of the property,
- Confirm that it has not previously been used for another citizenship application,
- Review the valuation report, transfer documents, bank transfer receipts and seller information.
If a previous use is detected, the file will be rejected or returned with a clear statement that this property is not eligible.
7. Multiple Properties and Multiple Families: What Is Allowed?
The good news is that the law does not prohibit families or investors from using different properties in a flexible way, as long as:
- Each citizenship investment is backed by distinct real estate assets, and
- The minimum threshold (e.g. USD 400,000) is satisfied per main applicant.
Some practical examples:
7.1 Two brothers, two separate investments
- Brother A purchases Apartment 1 (value: USD 450,000) and applies for citizenship with his spouse and children.
- Brother B purchases Apartment 2 (value: USD 420,000) and applies for citizenship with his own spouse and children.
This structure is fully compliant. Each family has a different property and makes its own qualifying investment.
7.2 One investor, multiple properties in the same application
An investor can also:
- Buy several apartments or a combination of apartments and commercial units that reach or exceed the required threshold in total,
- Use this portfolio of properties as the basis of one single citizenship application for himself and his family.
In this case:
- Each property in the mix is locked for citizenship use once the application is approved.
- Those properties cannot later be used as the basis of another investment for someone else.
7.3 New family member later: adult children or married children
A frequent question is:
“If my adult child marries later, can they use the same property as the basis for their own citizenship application?”
The answer is no, if the property has already been used for the parent’s citizenship application. However:
- If the child was included as a minor in the original family application, they are already a Turkish citizen.
- If not, they must make their own independent investment with new properties that have never been used for citizenship.
8. Practical Compliance Tips for Foreign Investors and Families
To avoid costly mistakes and rejected applications, investors should follow some practical guidelines:
8.1 Insist on a clear property history report
Before buying, request from your lawyer and/or reputable consultant:
- A title deed check showing whether the property has previously been used in a citizenship application,
- Confirmation that there is no prior annotation or use as a citizenship investment,
- Verification of the seller’s identity and possible prior links to the citizenship program.
Do not rely solely on the developer or broker’s assurances.
8.2 Avoid “too good to be true” multiple-citizenship promises
If you are told that:
- the same apartment can be reused for several families, or
- you can “borrow” a friend’s property for your own citizenship application,
take this as a serious red flag. It usually means that the proposed structure is either illegal or at least not in line with administrative practice and will likely be blocked by the authorities.
8.3 Plan family structure in advance
Before making the purchase, decide:
- Who will be the main applicant,
- Which spouse and children will be included in the same file,
- Whether any adult children or relatives will need separate investments and thus different properties.
Proper planning at the beginning can save your family from uncertainty and disagreements later.
8.4 Work with independent legal counsel
Using independent legal counsel not tied to the developer or broker allows you to:
- Have the contract of sale, payment plan and citizenship structure reviewed purely from a legal and compliance perspective,
- Identify risks related to reuse of the same property, artificial valuation, or suspicious transaction chains,
- Design a structure that is robust against possible future regulatory changes.
9. Consequences of Violating the “One Property – One Citizenship Investment” Rule
If an investor or advisor attempts to use the same property for multiple citizenship applications, the main consequences may include:
- Rejection of the citizenship file
The most immediate result is that the Ministry refuses the application, citing non-compliance with investment requirements. - Loss of time and financial resources
The investor may have already:- Purchased the property,
- Paid taxes, fees, and commission,
- Spent money on valuation reports, notarizations and translations.
A rejected application may force them to buy new property or restructure the investment.
- Increased scrutiny in future applications
Once a risky structure is detected, the authorities may look more closely at the investor’s other transactions and at the advisor or developer involved. - Potential legal and administrative issues
In extreme cases involving fraudulent valuation, sham sales or circular transactions, the conduct may attract:- Administrative sanctions,
- Tax audits, or
- Even criminal investigation if there is evidence of intentional wrongdoing.
10. Key Takeaways for SEO and Practical Guidance
For foreign families and investors exploring Turkish citizenship by investment through real estate, the main points you should remember are:
- One property can only be used once as the basis of a citizenship application – it cannot be “recycled” for multiple families.
- The rule applies regardless of whether the second applicant is:
- A relative (brother, cousin, in-law),
- A friend,
- A completely unrelated buyer.
- A family (main applicant, spouse and minor children) can all be included in one application based on the same investment, but this does not allow re-use of the property later.
- Authorities use title deed annotations, internal databases and history checks** to ensure the same property is not used again.
- Any structure promising two citizenships from one apartment or similar advantages is likely to be non-compliant and risky.
- The safest way to secure citizenship for multiple families or adult children is to plan separate, independent real estate investments that each meet the minimum legal threshold and have never before been used for citizenship.
Conclusion
The Turkish citizenship by investment program continues to attract many foreign families who want a new passport, residence, and investment base in a dynamic country. However, the program is also under constant domestic and international scrutiny.
The principle that one property can generate only one citizenship investment is central to the credibility of the system. Foreign investors should therefore:
- Treat the rule as strict and non-negotiable,
- Avoid questionable schemes that try to reuse the same property for multiple families, and
- Seek independent legal advice before committing to any real estate transaction intended for citizenship purposes.
By structuring your investment in a compliant way from the beginning, you protect not only your own application but also your family’s future in Turkey.
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