Short answer: The omnibus law dated 4 June adds Provisional Article 19 to Corporate Tax Law No. 5520, introducing a new Turkish wealth amnesty (“Varlık Barışı”). Cash, gold, foreign currency, securities and other capital-market instruments held abroad — or held in Turkey but absent from statutory books — can be declared to banks or intermediary institutions until 31 July 2027 and brought into the formal economy. The real novelty this time is that the tax, normally 5%, can fall all the way to 0% depending on how long the asset is committed to TRY-denominated instruments.
Wealth amnesty is not a new instrument — this is a familiar sequel
Turkey has revisited the idea of bringing undeclared and offshore assets onto the books at a low tax cost roughly every few years. From Law No. 5811 in 2008 through 2013, 2016 (Law 6736), 2018 (7143), 2019, 2021 and most recently Provisional Article 15 added to the Corporate Tax Law by Law No. 7417 in 2022, there is a clear lineage. The new Provisional Article 19 is effectively the successor to that 2022 measure, grafted onto the very same statutory backbone.
The contrast with prior versions is telling. The 2022 scheme set tiered rates of 1–3% for foreign assets and a flat 3% for domestic ones, with the rate dropping to 0% if foreign assets were held for one year. The new article turns that logic into a far more finely tuned incentive grid.
What the provision actually says
The article covers two distinct asset pools. Assets held abroad (cash, gold, FX, securities and other capital-market instruments owned by individuals or legal entities) must be declared to a bank or intermediary by 31 July 2027 and, within two months of the declaration, transferred to Turkish accounts or physically brought in and deposited. Assets located in Turkey but missing from statutory books must likewise be declared by 31 July 2027 and substantiated by depositing them with a bank or intermediary as of the declaration date.
Taxpayers who keep books record these assets in their statutory books on the declaration date. Those on a balance-sheet basis open a special fund account on the liabilities side; that fund cannot be withdrawn for two years, may only be added to capital, and is not taxed upon liquidation. Persons with no income- or corporate-tax liability benefit without these bookkeeping and fund conditions, provided they bring in and deposit the assets in time.
The real novelty: the rate is now tied to a commitment grid
Banks and intermediaries collect, as a rule, a 5% tax on the declared value upfront and remit it as withholding agents. But if the asset is committed to be held for a set period in specific TRY instruments — time deposits, government domestic debt securities and lease certificates issued under Law No. 4749, or venture capital investment funds — the rate steps down:
- At least 5 years → 0%
- At least 4 years → 1%
- At least 3 years → 2%
- At least 2 years → 3%
- At least 1 year → 4%
- No commitment → 5%
There is also a clock. Declarations made between 1 January and 31 July 2027 carry a half-point surcharge on each rate; if the President extends the deadline, later declarations carry a further half point, for a total one-point increase. In short, declaring the same asset in 2026 is cheaper than declaring it in 2027. No stamp duty is levied on the commitment letters.
This design is better read as steering than as a simple incentive. The state is willing to take the tax to zero; what it wants in return, beyond repatriation, is for the money to stay for the long term in TRY instruments and domestic capital markets. The rate grid is, in effect, a de-dollarization and domestic-investment tool.
Why this matters for venture capital
The inclusion of venture capital investment funds (GSYF) among the instruments that qualify for the 0% rate is, from our vantage point, the most interesting detail. An asset held in a VC fund for five years is taxed at 0% — and the fund sits on the same privileged list as government bonds and time deposits. That is a direct fiscal incentive for a portion of amnesty capital to flow into venture capital funds.
In theory this is a channel that could enlarge Turkey’s domestic VC pool. In practice, caution is warranted: a five-year hold naturally aligns with an illiquid, long-horizon asset class, so the tax break and the nature of the investment reinforce one another here. Still, the 0% rate should never be the sole reason for a VC fund commitment; the fund’s strategy, manager and portfolio must be assessed on their own merits.
The shield is real, but conditional
Paragraph eight provides that no tax inspection or assessment will be carried out on amounts corresponding to declared assets. Three fine points should not be missed:
First, the protection is not absolute. The article expressly states that “measures required under other legislation are not affected.” The amnesty is a tax shield; it is not a money-laundering mechanism for criminally derived assets. It offers no refuge for assets whose source is problematic from a criminal or administrative standpoint.
Second, protection depends on compliance. If the asset is not brought in or deposited in time, if the tax is not paid on time, or if a hold commitment is breached, the paragraph-eight shield is lost. In that case, taxes that failed to accrue on time are collected with late interest but without a tax-loss penalty — no penalty, but interest and loss of protection.
Third, the base-difference offset is precise: if an inspection started for other reasons finds a tax-base difference traced to the declared assets, no assessment is made so long as the declared amount equals or exceeds that difference; only the excess is taxed if the difference is larger. Conversely, base differences arising from reasons unrelated to the declared assets are not offset against these amounts.
What to do in practice
A few practical themes stand out. Timing is a cost line: declaring within 2026 avoids the half-point increase in 2027 — moving early has a direct financial payoff. The commitment is an investment decision: the five-year hold required for the 0% rate means locking the asset into specific instruments for five years, and should be planned alongside liquidity needs and investment strategy, not chosen on the tax rate alone. Bookkeeping and the fund require care: opening the special fund account correctly and observing the two-year withdrawal ban are critical to keeping the protection. And finally, source matters: if the asset’s legal source is unclear, the amnesty alone provides no shield.
The Vircon take
Provisional Article 19 can be read both as a public-finance instrument and as a capital-markets policy. The goal of attracting and formalizing capital is understandable; the grid that takes the rate to zero is a clever design that steers money into long-term TRY instruments and — interestingly for us — into venture capital funds. At the same time, the long-run effect of successive amnesties on the culture of voluntary tax compliance remains an open question.
Our emphasis, as advisers, is this: the measure opens a window of opportunity, but it is not an automatic “clean slate.” Rate optimization, commitment term, bookkeeping and — above all — the source of the asset are factors to be weighed together before any decision. Structured well, it is a meaningful cost advantage; structured poorly, it is an area where you can lose the very protection you thought you had secured.
This article is for general information only and does not constitute legal opinion or tax advice. We recommend obtaining professional support for your specific situation.
