Turkish Citizenship by Investment: Procedural Update on Property Valuation

Understanding the New TTB System

The Turkish government has introduced a significant administrative update to the Citizenship by Investment (CBI) program. Starting December 9, 2024, the traditional property valuation report system will transition to a new framework. The primary change is the introduction of the Property Acquisition Amount Determination Certificate, known as the TTB (Taşınmaz Edinim Bedeli Belirleme Belgesi).

This certificate replaces the previous valuation reports issued by private firms. The goal is to standardize property values and ensure that all investments meet the legal minimums required for citizenship. The TTB is issued through the TADEBİS application by GEDAŞ, a state-authorized entity under the Ministry of Environment, Urbanization, and Climate Change.

Key Changes to Property Valuation Reports

Previously, investors hired independent valuation experts to assess property value. Under the new rules, the process is centralized. The TTB serves as the official confirmation that a property qualifies for the citizenship program. This shift aims to prevent price manipulation and provide a more transparent environment for foreign buyers.

The TTB will specifically verify if the purchase price aligns with the market value determined by the government's digital infrastructure. This ensures that the investment amount recorded in the title deed (Tapu) is accurate and legally sufficient for the citizenship application.

Current Investment Thresholds for Turkish Citizenship

While the administrative process is changing, the financial requirements for the CBI program remain the same. Investors must meet the following thresholds based on their purchase date:

• $400,000 Minimum: For properties purchased on or after September 19, 2018.
• $1,000,000 Minimum: For properties purchased between January 12, 2017, and September 18, 2018.

Investors must maintain ownership of the property for at least three years to remain eligible for citizenship. The TTB will be the primary document used to prove these thresholds are met during the application phase.

How to Obtain the TTB via WebTapu

The process for obtaining the TTB is integrated into the existing WebTapu and TADEBİS systems. Investors or their legal representatives must follow these steps:

• Log in to the WebTapu system.
• Submit an application for the Property Acquisition Amount Determination Certificate.
• The request is routed to GEDAŞ through the TADEBİS portal.
• GEDAŞ conducts the assessment and issues the TTB.

This digital workflow reduces the need for physical paperwork and streamlines the communication between the Land Registry and the valuation authorities.

Validity and Technical Requirements

The TTB comes with specific rules regarding its usage and expiration. Investors should be aware of the following technical details:

• Six-Month Validity: The TTB is valid for six months from the date of issuance. If the title deed transfer does not occur within this window, a new certificate must be obtained.
• Single Certificate Rule: A TTB is generally required for each property involved in the citizenship application.
• Public Institution Exceptions: Transactions involving public institutions or Real Estate Investment Trusts (REITs) may follow different valuation protocols, though the TTB remains the standard for most private sales.

Impact on Current and Future Applications

For investors currently in the process of buying property, the timing is critical. Applications submitted before December 9, 2024, may still follow the old valuation report rules. However, any transaction finalized after this date must comply with the TTB requirement.

This update does not change the legal rights of investors. It simply changes the document used to prove the investment value. By centralizing the valuation process, the Turkish government aims to speed up the verification stage of the citizenship application. This should lead to fewer delays caused by discrepancies in private valuation reports.

Strategic Advice for Investors

Investors should ensure their legal counsel is familiar with the TADEBİS system. It is important to verify that the property's sale price matches the value that GEDAŞ is likely to approve. Working with experienced consultants will help navigate this transition and ensure that the TTB is secured without administrative errors. The focus remains on transparency and compliance with the updated 2024 guidelines.

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