Dual Citizenship and Turkey: Rules and Implications for HNW

Türkiye allows dual — and multiple — citizenship. It does not require you to renounce your original nationality when you naturalise as a Turkish citizen. That is the short answer, and it is the reason so many high-net-worth families use the Turkish Citizenship by Investment (CBI) route to add a second passport without giving up their first. The complexity is not on the Turkish side. It is on the side of your home country: some nationalities allow dual citizenship freely, some restrict it, some require formal renunciation upon foreign naturalisation, and a small number treat renunciation as legally irrelevant. This guide, written by GMC (Global Mobility Capital®), a Turkish-CBI specialist advisory with offices in Istanbul, Athens and Dubai, walks you through the Turkish legal position, the home-country patterns that matter most for our HNW clients, and the practical questions — tax, military service, inheritance, voting, property — that dual nationals face after naturalisation.

1. The Turkish Legal Position on Dual Citizenship

Türkiye's approach is codified in the Turkish Citizenship Law No. 5901 (Türk Vatandaşlığı Kanunu), as amended. Two articles do most of the work.

Article 44 — Acquisition of Turkish citizenship without loss of original nationality. Under Article 44, a foreign national who acquires Turkish citizenship by naturalisation, marriage, adoption, or the exceptional investor route is not required to renounce their original nationality as a matter of Turkish law. The Turkish state does not ask for evidence of renunciation, nor does it condition the citizenship decree on any such step.

Article 43 — Retention of Turkish citizenship after acquiring a foreign nationality. Türk citizens who acquire a foreign nationality do not automatically lose their Turkish citizenship. They may notify the Ministry of Interior of the acquisition, but their Turkish status remains intact unless they take the formal step of applying for release (vatandaşlıktan çıkma izni) under a separate procedure.

The practical implication is clean: from Türkiye's side, you can hold Turkish citizenship together with any other nationality.

Where Türkiye records dual status

The Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü (NVI) — the Directorate General of Civil Registration and Nationality — records dual nationals in its population registry. Once you are naturalised, your dual status is a matter of civil record; you do not need to declare your other nationality every time you deal with a Turkish authority.

2. Does Your Home Country Allow Dual Citizenship?

This is the question that determines whether the Turkish route is straightforward for you, complicated, or actively contested. The pattern varies dramatically by nationality.

The rule that catches families out is the Chinese renunciation rule: a PRC national who voluntarily acquires foreign citizenship is regarded by Chinese law as having lost Chinese nationality. This is not a Turkish problem — Türkiye welcomes the new citizen — but it is a genuine consequence in the home country that must be planned for. The Indian OCI card is a different design: it grants many practical rights (entry, work, property) without being citizenship in law.

For Iranian, Saudi and Emirati clients, the picture is subtler: the Turkish citizenship itself is unaffected, but disclosure obligations, permission requirements and travel implications inside the home country need individual assessment. GMC's Dubai office works these cases regularly.

3. Tax Implications of Turkish Dual Nationality

A common misconception is that becoming a Turkish citizen creates a Turkish tax liability. It does not — Türkiye taxes on the basis of residence, not citizenship. A dual national who lives outside Türkiye is generally not a Turkish tax resident. Residence, under Turkish domestic tax law (Income Tax Law No. 193), is triggered principally by domicile or by physical presence exceeding 183 days in a calendar year, subject to treaty tiebreakers.

The important tax question is what your home country does.

• United States. The US is the global outlier: it taxes on the basis of citizenship. US citizens who acquire Turkish citizenship remain fully subject to US federal tax on worldwide income, and to FBAR and FATCA reporting, regardless of where they live. Adding Turkish citizenship does not change that.
• UK, Canada, Australia, EU member states. All tax on residence, not citizenship. A UK citizen who becomes tax-resident in Türkiye and non-resident in the UK is generally outside UK income tax on foreign income (statutory residence test applies).
• Gulf states. No personal income tax on residents in most Gulf jurisdictions, so the tax layer often does not bite. What matters is whether the home country restricts the citizenship itself.

Türkiye has a wide network of double-tax treaties — over 85 in force — which normally resolves double-taxation questions cleanly. Confirm your specific treaty position with GMC before restructuring.

4. Military Service for Male Dual Nationals

Turkish male citizens are subject to compulsory military service under Military Service Law No. 1111, as amended by Law No. 7146 (Bedelli Askerlik) and subsequent legislation. This applies to naturalised citizens in principle, but there are important nuances.

• Age at naturalisation. Foreign males who acquire Turkish citizenship after a certain age — currently 22 — are typically not liable for active service.
• Bedelli Askerlik (paid military service). Eligible male citizens can discharge the obligation through payment and a short basic training. As of 2025, the fee has been in the range of USD 5,000–7,000 equivalent, but the figure is periodically re-set by government decree.
• Deferrals. Full-time students, residents abroad, and some other categories can defer. Dual nationals resident outside Türkiye are typically not called up during their absence.

For HNW families adding Turkish citizenship for a son who is already an adult and resident outside Türkiye, military service is a manageable, formal issue — not a live risk.

5. Inheritance, Property and Voting Rights

Once you are a Turkish citizen, the full slate of civic rights and obligations attaches, subject only to certain public-office restrictions on new citizens.

• Property ownership. Turkish citizens have no foreign-buyer restrictions and no area limits. You are treated exactly as any born citizen would be.
• Inheritance. Turkish citizens' worldwide assets can be dealt with under Turkish succession law where jurisdiction attaches. Estate planning across two citizenships needs specialist advice; the Turkish forced-heirship rules for legal reserve (mahfuz hisse) will apply to assets subject to Turkish law.
• Voting. Turkish citizens vote in Turkish general elections. Dual nationals resident abroad vote at Turkish consulates or through the postal-vote mechanism.
• Consular protection. Türkiye extends full consular protection to its dual citizens outside Türkiye. Inside a country of which you are also a national, that country generally does not recognise Turkish consular access.
• Passport. Dual nationals hold a full Turkish passport, valid for ten years, with visa-free or visa-on-arrival access to 110+ destinations.

6. Practical Question: When Do You Declare?

This is where advisory judgement matters. The disclosure decisions depend on your home country's rules and your personal profile.

• US, UK, Canada, EU citizens. No obligation to hide anything; disclosure to home tax authorities is usually already handled by FATCA/CRS automatic exchange. Straightforward.
• China, Iran, Saudi Arabia. Disclosure to the home country carries real consequences and should not be volunteered outside of a structured legal plan.
• India. Naturalisation is disclosable in India; OCI status is applied for separately after naturalisation.

GMC does not advise clients to breach their home-country legal obligations. We do advise clients on how to sequence and structure disclosure so that the addition of Turkish citizenship achieves its purpose without triggering unintended consequences.

Sources

• Turkish Citizenship Law No. 5901 (Türk Vatandaşlığı Kanunu), Articles 43, 44 — Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü: https://www.nvi.gov.tr/
• Turkish Presidency (citizenship decrees): https://www.tccb.gov.tr/
• Ministry of Foreign Affairs (consular and dual-citizenship information): https://www.mfa.gov.tr/
• Turkish Presidency Investment Office: https://www.invest.gov.tr/
• Military Service Law No. 1111, as amended — Ministry of National Defence
• Turkish Statistical Institute (TÜİK): https://www.tuik.gov.tr/
• Turkish Central Bank (TCMB): https://www.tcmb.gov.tr/