Annual Report for Turkish CBI in 2023 –what has happened and what to expect

The Turkish Citizenship by Investment (CBI) program has consistently ranked among the most popular citizenship programs since its inception. As the leading provider of the Turkish Citizenship by Investment (CBI) program, Globevisa has not only submitted the initial application and secured the first approval but has also closely monitored every policy change since then. In contrast to programs in the Caribbean Islands that require a donation or property ownership for a minimum of five years, Turkey’s requirements are more accessible: applicants can either make a bank deposit of USD 500,000 for three years or purchase a property worth USD 400,000 and hold it for three years.

On December 21, 2022, the government implemented several policy changes regarding the Turkish Citizenship by Investment (CBI) program:

1. Properties owned by foreigners within the preceding three years are no longer eligible for the CBI.

2. Properties held by companies with foreign ownership exceeding 51% are not eligible for CBI.

3. Properties owned by companies with Turkish nationals but who obtained their passports through the CBI program are also not eligible for CBI.

4. Partial ownership shares of properties, regardless of their value, are not eligible for CBI. Sole ownership is now mandatory.

The government’s efforts to regulate the market continue beyond the previous policy changes.

Starting in 2023, the Turkish government established a new department named Gabim to scrutinize all property evaluation reports to ensure fair and accurate property valuations. This has a significant impact on CBI applicants, given that the minimum threshold for citizenship application is set at USD 400,000. If the evaluation report falls below this value, the applicant becomes 

ineligible to apply.

Gabim was previously a private entity but has now become a government and publicly owned. As per their website statement: “On 28.09.2020, Turkish Appraisal Experts Association and Central Registry Agency Inc. entered into a share transfer agreement, transferring all shares of our Company to Central Registry Agency A.Ş. for a nominal price. On 05.01.2021, our company’s title was registered and announced in the Istanbul Trade Registry as MKK GAYRİMENKUL BİLGİ MERKEZİ ANONİM ŞİRKETİ (GABİM).”

Here are some statistics regarding GABİM’s report control activities in 2023 up to September 30, 2023:

· A total of 41,416 reports were generated via TADEBIS.

· 515 separate control reports were issued to 45 different evaluation institutions.

· Based on the control reports, 326 reports that indicated excessively high or low prices were invalidated.

· The cancellation rate for reports prepared via TADEBIS was 0.78%.

· The average time for controlling a report generated via TADEBIS is one day.

· As a result of violations of the Procedures and Principles identified during the controls, 62 participants faced work slowdowns on 129 occasions, with the duration of these slowdowns ranging from 10 days to 81 days. Additionally, the relevant reports included separate error scores for Experts, Inspectors, and Responsible Appraisers.

· The average waiting period for reports placed on hold, for which control reports are prepared is 10 days.

Source: https://mkkgabim.com.tr/

Gabim typically compares the prices of nearby second-hand properties and occasionally conducts on-site checks to verify the property values. This process has a significant impact on applicants. Here’s how it works:

All properties must undergo an evaluation report. The evaluation report is then uploaded to the government website for Gabim’s review.

On average, the review process takes about 1 to 2 weeks.

Applicants should take note that only the review result, and not just the initial evaluation report, is crucial for determining eligibility. To be eligible to apply for the CBI program, the review result must indicate a value above USD 400,000.

In order to avoid the risk of property valuation results, Globevisa since then only cooperate with developers who provide properties with an approved report.

In December of 2023, the Turkish CBI started to collect the main applicant’s non-criminal record and announced that the threshold will increase from the current USD400K to USD 600K from 2024. Globevisa always response with prompt action to supplement the additional documents and follow all new rules.

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