CRS Reporting in Turkey & Turkish Citizenship by Investment: What Investors Should Know

What is CRS?

The Common Reporting Standard (CRS) is an international framework developed by the OECD for the automatic exchange of financial account information between participating countries. Its purpose is to combat tax evasion by ensuring that financial institutions report certain account details of foreign tax residents to their local tax authorities, which may then be shared with the relevant foreign jurisdictions.

Is Turkey part of CRS?

Yes. Turkey is a participating jurisdiction under the CRS framework. Turkish financial institutions are required to identify the tax residency of account holders and report relevant information in accordance with CRS rules.

If I invest in Turkey, will my bank information be shared with my home country?

Potentially yes, but only under specific conditions. CRS reporting is based on tax residency, not citizenship. If you open a bank account in Turkey and are considered a tax resident of another CRS-participating country, Turkish banks may report certain financial information to the Turkish tax authorities, which can then be exchanged with the tax authorities of your country of tax residence.

However:

• CRS does not apply automatically to every account.

• Only reportable accounts meeting CRS thresholds and criteria are included.

• Information shared is limited to specific financial data (such as account balance and certain income) and does not include transaction-level details.

  
  

Does obtaining Turkish citizenship trigger CRS reporting?

No. Acquiring Turkish citizenship alone does not trigger CRS reporting. CRS looks at where you are a tax resident, not which passport you hold. Under Turkish tax law, individuals are generally considered tax residents in Türkiye only if they stay in Türkiye for at least 183 days within a calendar year. If an individual resides in Türkiye for less than 183 days in a given calendar year, they are typically not regarded as Turkish tax residents, and this alone does not change their CRS position. Many investors obtain Turkish citizenship while remaining tax residents of another country, and the CRS position remains unchanged unless their tax residency status changes.

What about Turkish Citizenship by Investment routes?

For investors applying under the Turkish Citizenship by Investment (TCBI) program, CRS implications depend on the chosen investment route:

1. Bank Deposit Route

If funds are placed in a Turkish bank:

• In practice, banks may request a CRS self-certification form as part of their internal compliance procedures; however, in many cases this form is not separately requested unless triggered by the client’s declared tax residency or the bank’s risk assessment.

• The investor must declare their tax residency.

• Reporting, if any, will be made based on the declared tax residency and CRS rules.

2. Private Pension System (BES)

The Turkish Private Pension System is regulated and fund-based. While pension providers also follow CRS compliance requirements, reporting still depends on the investor’s tax residency and the classification of the account under CRS.

3. Real Estate Investment

Direct real estate ownership is not subject to CRS reporting in Turkey. CRS applies to financial accounts, not to immovable property ownership.

Are there expected changes to CRS in the coming years?

Globally, CRS continues to evolve, with discussions around:

• Expanded reporting scope

• Increased data standardisation

• Tighter compliance requirements

However, as of today, there is no announced exemption or special CRS regime specifically linked to Turkish Citizenship by Investment. Any future changes would apply broadly across participating jurisdictions, not uniquely to Turkey.

Key Takeaways for Investors

• Turkey participates in CRS.

• CRS reporting is based on tax residency, not citizenship.

• Opening a bank account in Turkey does not automatically mean information is shared.

• Real estate investments are outside the scope of CRS.

• Proper legal and tax planning is essential.

How IGA Law Firm Assists

IGA Law Firm provides legal guidance to investors throughout the Turkish Citizenship by Investment process, including coordination with banks, CRS self-certification procedures, and compliance-focused structuring. While we do not provide tax advisory services, we work closely with clients’ tax advisors to ensure transparency and regulatory alignment.