Amendments have been brought to the Guide on the Regulation Concerning the Implementation of the Turkish Citizenship Law attached to the Circular dated May 30, 2019 and numbered 2019/5(the “Guide”) together with the announcement published on December 20, 2022 by the General Directorate of Land Registry and Cadastre, Department of Foreign Affairs. Amendments envisaged in the Guide shall be entered into force as of January 1, 2023. Within this scope;

1- Amendments Regarding the Parties and the Real Estate

• The second-hand real estate subject to sale or preliminary sales agreement should not have been transferred to a Turkish citizen or legal entity by any foreign real person within the last 3 years. As a result, the second-hand property must be owned by a Turkish citizen for at least 3 years. Acquisitions arising from contracts of construction are determined as an exception to this rule.

• Real estates subject to sale or preliminary sales agreement cannot be registered in the name of foreign persons or Turkish first degree relatives (blood or marital) of foreing buyers being real person in the land registry.

• A real estate can only be subject to citizenship acquisition once. In case that the real estate has been subjected to citizenship before, it shall not be possible to reapply for a certificate of conformity with the aforesaid real estate.

• In order for incomplete real estates to be subjected to the application and an valuation report to be obtained, the construction of the relevant real estate must have been initiated. For these real estates, the “current value in case of its completion” on the report date will be based on.

2- Amendments Regarding Shares of Sale

• Applying for the acquisition of citizenship shall not be possible through a jointly owned property. Pursuant to the relevant legislation, purchasing of a high-value property jointly by more than one person and applying for acquisition of Turkish citizenship cannot be possible. For instance, when a property with a value of USD 800.000,00 is purchased by two foreign people in a way to form a jointly-ownership, the aforesaid property cannot be subject to the acquisition of citizenship.

3- Amendments Regarding the Preliminary Sales Agreements

• Regarding the applications made based on a preliminary sales agreement, the minimum amount of USD 400.000,00 stipulated under the relevant legislation must be provided with a single contract. In other words, while it is possible to subject more than one real estate to a preliminary sales agreement, applications based on more than one preliminary sales agreement shall not be accepted.

• In case that the real estate purchased through a sale agreement does not meet the amount required for the acquisition of citizenship, the remaining amount shall not be completed with a preliminary sales agreement.

• Valuation reports prepared up to at the most 3 months prior to the date of issuance of the preliminary sales agreement before notary shall be processed. In the presence of these valuation reports, a separate valuation report shall not be sought before the annotation date.

• In the preliminary sales contract, the foreign exchange purchase document must be issued for the minimum amount paid in advance and on the contract date at the latest.

4– Other Significant Amendments

• While it is possible to establish all kinds of annotations and limited real rights in registered immovables, it has been decided to exclude the annotation for preliminary sales.

• Transfer of the payment from the buyer or related persons to the accounts of the seller or related persons (his/her proxy, spouse, right holder of the construction contract in return for flat, lien or mortgage creditor, account of the company owner, etc.) shall be allowed.

• It has been made possible to optionally use secure payment systems offered by banks in the transfer/payment of the price of real estate.