US$400,000 real estate Türkiye CBI: Regulations, areas, and the three-year holding requirement

The US$400,000 real estate Türkiye CBI is the most popular investment option under the Türkiyecitizenship by investment programme, accounting for over 90% of all applications approved each year. This option allows investors to purchase one or more properties with a total minimum value of US$400,000 according to the official SPK valuation, hold the assets for three years, and in return, obtain citizenship for the entire family.

Unlike the bank deposit or government bond options, real estate investment in Türkiye Citizenship by Investment programme Türkiye provides tangible assets with the potential for capital appreciation and rental income. However, this option also involves the most complex legal regulations of the four investment routes. This article provides a detailed analysis of the entire legal framework, transaction process, eligible property types, and risks that investors need to anticipate.

Legal framework of the US$400,000 real estate Türkiye CBI

The legal basis for the real estate investment option lies in Article 12 of the Citizenship Law No. 5901 and Article 20 of the Regulation on the Implementation of the Citizenship Law. These two documents stipulate all conditions, investment thresholds, and holding periods.

According to current regulations as of 2026, the minimum investment threshold is US$400,000. This level has been applied since June 2022 (increased from the previous US$250,000) and has remained stable for four years. Note specifically: the US$400,000 value is not the actual purchase price, but the official SPK valuation. This is one of the most common misconceptions among new investors entering the market.

The implementing agencies consist of three main bodies: the General Directorate of Land Registry and Cadastre (TKGM) of Türkiye, which handles the TAPU title deed transfer and records the transaction restriction; the Ministry of Environment, Urbanisation and Climate Change, which issues the Certificate of Conformity; and the Presidency of Migration Management of Türkiye, which processes residence permit applications and citizenship applications.

Five core conditions of the US$400,000 real estate Türkiye CBI

For a property to be recognised as eligible for the US$400,000 real estate Türkiye CBI application, the transaction must simultaneously meet the following five conditions.

Condition 1: SPK valuation ≥ US$400,000

The property must be independently valued by a valuation firm licensed by the Capital Markets Board of Türkiye (SPK – Sermaye Piyasası Kurulu). The valuation report must confirm a minimum value of US$400,000. This value is entirely independent of the actual purchase price stated in the contract.

The valuation process requires two sworn appraisers from an SPK-licensed firm. They inspect legal records, cross-reference regional market prices, and assess the physical condition of the property. The report is 20 to 35 pages long, completed within three to seven working days, and costs between US$300-500.

If the valuation is lower than US$400,000, the application will be rejected even if the actual purchase price exceeds this amount. Investors have two options: add another property so the total valuation reaches the threshold, or switch to a property with a higher valuation.

Condition 2: The seller must be a Turkish citizen or company

The property must be purchased directly from a Turkish citizen or a company registered in Türkiye. Purchases from foreign sellers are automatically excluded from the CBI programme, even if all other conditions are met.

This regulation is intended to prevent foreign investors from repeatedly buying and selling the same property to exploit the programme. If the seller is a company, it must have a valid business registration number in Türkiye and complete legal documentation.

Condition 3: The property has not been used for another CBI application within three years

A property that has been used for another investor’s CBI application in the last three years will not be eligible. This regulation is designed to prevent the “recycling” of assets through multiple citizenship applications.

In practice, after an investor completes the three-year TAPU holding period and sells the property, that property cannot be used for a subsequent CBI application for another three years. The second buyer can only receive ownership rights without the associated citizenship benefits.

Condition 4: Payment via the banking system and DAB certificate

The entire transaction must be paid through the Turkish banking system. Cash payments, informal payments, or payments via third parties are not recognised.

Investors are required to transfer USD or EURO from an overseas account to an account at a Turkish bank and convert it into Lira at the Central Bank of the Republic of Türkiye (TCMB). After the conversion transaction, the bank issues a DAB (Döviz Alım Belgesi – Foreign Exchange Purchase Certificate). This certificate is a mandatory document in the CBI application and has been required since January 2022.

The total DAB value must be ≥ US$400,000 and match the TAPU value and the SPK valuation. If these three figures are not consistent, the Land Registry Office will refuse to record the transaction restriction — meaning the CBI application will be disqualified.

Condition 5: Three-year transaction restriction note on the TAPU

When transferring the property title, a special note must be inscribed directly onto the title deed (TAPU). This note contains the Turkish text “satılmayacağına dair şerh” — loosely translated: “cannot be sold pursuant to Article 20 of the Regulation on the Implementation of the Citizenship Law No. 5901”.

The note is valid for three years from the date of title transfer. During this period, the investor cannot sell, transfer, or mortgage the property. After three years, the note is automatically removed, and the investor has full ownership rights, including the right to sell without affecting the citizenship already granted.

Eligible property types

The implementing regulation allows for a wide range of property types within the CBI programme. According to announcements from the General Directorate of Land Registry and Cadastre of Türkiye, the following types are all recognised.

• Apartment units (newly built or resale)
• Townhouses and detached villas
• Commercial premises (shops, offices, warehouses)
• Full commercial buildings
• Plots of land with legal structures that are completed or under construction with a valid building permit

Investors can combine multiple properties to reach the US$400,000 threshold. For example, an apartment valued at US$250,000 and a commercial premise valued at US$180,000 (total US$430,000) are both eligible. However, all properties must be transferred in the same transaction batch and registered simultaneously with the TKGM.

Properties under construction (off-plan) can also be eligible if the developer has a valid building permit and a preliminary TAPU. However, the legal risks for this type of asset are higher than for completed properties.

Some types of assets are not eligible, including: agricultural land without building permits, properties located in restricted military zones, properties with unresolved legal disputes, and shares in a project (only actual ownership of a property with a separate TAPU is recognised).

Popular investment areas in Türkiye

Although the programme does not limit geographical areas, some areas are prioritised by international investors due to their potential for capital appreciation, rental yields, and high liquidity.

Istanbul – Financial and commercial centre

Istanbul accounts for approximately 60-65% of all annual real estate CBI transactions. Central European-side districts such as Şişli, Beyoğlu, Beşiktaş, and Sarıyer attract high-net-worth investors due to their proximity to the Levent and Maslak business districts. These areas offer long-term rental yields of 4-6% and short-term (tourist) yields of 8-12%.

The Asian side of Istanbul, particularly the Kadıköy and Üsküdar districts, is chosen by middle-class investors for its more reasonable entry prices and stable residential communities. For a detailed analysis of these areas, please refer to the article Istanbul real estate Beyoğlu Sarıyer Beşiktaş.

Antalya – The Mediterranean tourism hub

Antalya stands out for its Mediterranean climate and is a leading tourist destination in Türkiye. This region has the highest short-term rental yields in the country (15-18% during peak season), making it suitable for investors pursuing a second-home model or tourist rentals. Notable districts include Konyaaltı, Lara, and Alanya. For detailed information, please refer to the article Antalya real estate.

Bodrum – The luxury resort peninsula

Bodrum is a luxury resort destination for the ultra-wealthy from the Middle East and Europe. Real estate here has a higher entry price (≥US$600,000 for a coastal villa) but offers stable capital appreciation potential and good liquidity for the high-end segment. Details are presented in Bodrum real estate.

Actual costs beyond the US$400,000 investment

Investors should budget a total of 7-12% on top of the property value to cover fees and taxes outside the purchase price. This is a common budgeting error for new investors.

• TAPU title deed transfer fee (Tapu Harcı): 4% of the TAPU value, which is legally split equally between buyer and seller at 2% each. In market practice, most contracts in Türkiye shift the entire 4% to the buyer. At a US$400,000 level, this amount is approximately US$16,000.
• VAT (KDV): 1% for apartments ≤150 m² purchased from the developer of the project, 8-18% for commercial real estate or apartments >150 m². Foreign buyers may be exempt from VAT if they meet the requirements regarding foreign currency conversion and do not resell for 1 year.
• SPK valuation fee: US$300-500 per report
• Legal and POA fees: US$1,500-3,000 depending on the complexity of the transaction
• Sworn translator fee at the Land Registry Office: 100-200 USD
• Mandatory DASK (earthquake) insurance: 0.1-0.2% of the property value per year
• Annual property tax: 0.1-0.6% of the TAPU value depending on the property type and area

Total costs outside the purchase price for a US$400,000 package usually fall between US$28,000-48,000. Investors need to add these costs when calculating the total capital required for a CBI application.

Rights to lease and operate during the three-year holding period

This is one of the strengths of this option compared to the deposit or bond options. Investors have the full right to rent out the property during the 3-year transaction restriction period. The TAPU note only prevents the sale or transfer of ownership, not the right to use and exploit the property.

With an average long-term rental yield of 4-6% and a short-term rental yield of 8-15% depending on the area, investors can recover 12-25% of their investment capital over 3 years of renting. Rental income is subject to progressive personal income tax from 15% to 40% if it exceeds the annual tax-free threshold (approximately 58,000 TRY/year according to 2026 regulations). For corporate owners, rental income is subject to a 23% corporate tax.

After 3 years, investors can sell the property with full freedom — the granted citizenship will not be revoked. Capital gains from selling property within the first 5 years are subject to a progressive tax of 15-40%, but the purchase price is adjusted according to the Producer Price Index (PPI) to offset the impact of inflation.

Risks and important considerations

The US$400,000 real estate CBI option in Türkiye has some specific risks that investors need to anticipate.

Risks undervaluation occurs when the contract purchase price is higher than the SPK valuation. In the 2024-2025 period, some developers created projects with artificially high valuations on contracts, but in reality, the SPK only valued them lower — leading to the rejection of CBI applications. In 2026, the real value monitoring system (Rayiç Bedel) tightened this, making it the most serious legal risk if investors do not conduct independent due diligence.

Risks Lira exchange rate volatility affects both asset value and rental yield. The Lira depreciated significantly in the 2022-2025 period. Although investors purchase in USD and the TAPU records the USD price, the actual market value of the property (when converted to USD to sell to another foreign investor) may decrease in line with Lira fluctuations.

Risks citizenship revocation occurs when a transaction shows signs of fraud regarding valuation or the source of funds. In 2024-2025, the Turkish Government revoked the citizenship of several investors found to have undervalued property on contracts to reduce taxes while still using the high price on the SPK report to apply for CBI. The post-citizenship transaction audit process has been strengthened since 2025.

Risks Anti-Money Laundering (AML) due diligence is becoming increasingly strict. Turkish banks require investors to provide full documentation proving the source of assets — including 6-12 months of bank statements, tax returns, business contracts, or employment contracts. The rejection rate for CBI applications due to AML reasons fluctuated between 10-15% in 2026 for investors from high-financial-risk markets.

Conclusion and next steps

The US$400,000 real estate CBI in Türkiye remains the most attractive option for Vietnamese investors who need tangible assets combined with citizenship. Core advantages include the potential for asset appreciation, rental cash flow of 4-15% per year, and the right to sell after 3 years while retaining citizenship. Success depends on selecting an asset with an accurate SPK valuation, a district with high liquidity, and a reputable developer.

To better understand the implementation steps, investors can refer to the article Turkish TAPU and the transfer process, Turkish Defter tax number and opening a Turkish bank account — 3 mandatory procedures before implementing a real estate transaction. Detailed information about the entire programme is summarized at Turkish CBI overview 2026.

Comparison with the other 3 options — US$500,000 government bonds, US$500,000 bank deposit and creating 50 jobs — the real estate option requires the lowest initial capital but is also the most legally complex. Investors should have an independent legal advisory team to appraise the entire transaction before deciding.