Turkey Property Valuation Report 2026 | Ekspertiz & TTB Guide

Introduction

When buying property in Istanbul, foreign buyers often encounter several different numbers attached to the same apartment.

For example:

• The seller asks for $350,000

• The buyer negotiates the price to $325,000

• The municipality has a much lower tax-related property value

• A professional valuer may estimate another figure

• The amount declared in the Tapu transaction has its own legal significance

• The Döviz Alım Belgesi records a currency-conversion amount

• A citizenship transaction may require a separate investment-value determination

These figures should not be treated as interchangeable.

One of the most important lessons for a foreign real-estate buyer in Türkiye is:

There is no single property “value” that serves every legal, tax, investment, banking and citizenship purpose.

A property's:

asking price

is not automatically its:

market value

and neither is automatically identical to its:

Emlak Vergisi value, Tapu transaction amount, valuation report value, DAB amount or citizenship investment value.

Understanding these differences can help a foreign buyer avoid:

• Overpaying

• Misunderstanding a developer's advertised price

• Confusing tax values with market prices

• Structuring Tapu payments incorrectly

• Misunderstanding citizenship thresholds

• Treating an appraisal as a guarantee of investment quality

This guide explains how property valuation works in Türkiye in 2026 and how foreign buyers should interpret the different numbers associated with a transaction.

What Is a Property Valuation Report in Turkey?

A property valuation report is generally referred to in Turkish as:

Taşınmaz Değerleme Raporu

In everyday real-estate conversations, you may also hear:

• Ekspertiz Raporu

• Eksper Raporu

• Gayrimenkul Değerleme Raporu

The objective of professional property valuation is to estimate the value of a particular property or property right at a particular date using recognized valuation methods and relevant market evidence.

Türkiye's Capital Markets Board — Sermaye Piyasası Kurulu, or SPK — describes real-estate valuation as the independent and impartial estimation of the probable value of real estate, real-estate projects, or related rights and benefits at a particular date under applicable valuation standards.

This is very different from asking a seller:

“How much do you want for the apartment?”

Asking Price vs Valuation

Suppose an Istanbul apartment is advertised for:

$350,000

That number is:

the seller's asking price.

It does not prove the property is worth $350,000.

The seller may have priced it:

• Aggressively

• Optimistically

• Based on another listing

• Based on expected negotiation

• Based on citizenship-buyer demand

• Based on their own financial needs

A professional valuation uses a different process.

The valuer attempts to estimate the property's value independently based on the relevant:

• Legal characteristics

• Physical characteristics

• Location

• Market evidence

• Comparable properties

• Valuation methodology

Therefore:

Asking Price ≠ Professional ValuationAsking Price vs Market Value

This distinction becomes extremely important in Istanbul because foreign buyers often compare properties through online listings.

Imagine three apartments in the same project.

Apartment A

Advertised at:

$290,000

Apartment B

Advertised at:

$340,000

Apartment C

Advertised at:

$375,000

That does not mean Apartment C is objectively worth approximately 29% more than Apartment A.

Possible explanations include:

• Different floor

• Different orientation

• Sea view

• Larger net area

• Better renovation

• Different owner expectations

• Different urgency to sell

Or simply:

one seller may be asking too much.

Therefore:

Listing prices are market evidence, but a listing price by itself is not proof of market value.

What Is Market Value?

In professional valuation, the objective is generally to estimate the property's likely value in the relevant market at a particular date, using accepted valuation standards and appropriate evidence.

For a buyer, the practical meaning is:

What price can reasonably be supported by the property's actual characteristics and market conditions?

That question is different from:

What does the seller want?

Negotiated Price vs Market Value

The final negotiated purchase price can also differ from estimated market value.

For example:

Valuation

$300,000

Seller Asking Price

$325,000

Final Negotiated Price

$292,000

The buyer may have negotiated a good deal.

Now consider:

Valuation

$300,000

Asking Price

$330,000

Final Purchase Price

$325,000

The buyer may have paid a premium.

But even that does not automatically mean the buyer made a bad decision.

Perhaps the apartment has:

• Exceptional view

• Unique floor plan

• Strategic location

• Furniture package

• Immediate availability

that the buyer values more highly.

Professional valuation is therefore a useful benchmark.

It is not a command telling buyer and seller what price they must agree to.

Does the Valuer Set the Sale Price?

No.

A property valuer does not normally decide what the buyer and seller are legally required to pay.

The parties still negotiate the commercial transaction.

A valuation may say:

Estimated Value: 15,000,000 TRY

while the buyer and seller agree:

15,500,000 TRY

or:

14,500,000 TRY

depending on negotiation.

The report provides valuation evidence.

It does not replace commercial agreement between the parties.

Why Is Property Valuation Important for Foreign Buyers?

Foreign investors can face several disadvantages compared with experienced local buyers.

They may be unfamiliar with:

• Neighborhood pricing

• Building quality differences

• Turkish property terminology

• Net vs gross square meters

• Developer pricing

• Resale discounts

• Local bargaining practices

An independent valuation can provide another reference point.

This is particularly useful where the buyer is considering:

• A high-value apartment

• A citizenship property

• An unfamiliar district

• An off-plan project

• An unusually expensive developer unit

Example: Foreign Buyer Overpricing Risk

A developer advertises:

2+1 Apartment — $420,000

The sales representative says:

“This is the normal market price in Istanbul.”

But comparable completed units nearby may trade much lower.

Without local market knowledge, a foreign buyer can mistake:

international marketing price

for:

local market value.

A professional valuation may help identify that difference.

What Does a Property Valuer Actually Evaluate?

A professional valuation is not based on one number.

Depending on the property and purpose of the report, the valuer can examine multiple categories of information.

These may include:

• Property location

• Cadastral information

• Title characteristics

• Independent-section information

• Legal status

• Building characteristics

• Property type

• Floor

• Size

• Physical condition

• Age

• Neighborhood characteristics

• Market comparables

• Rights or restrictions relevant to value

Professional valuation can also involve analysis of:

• Legal characteristics

• Market conditions

• Development potential

• Comparable evidence

• Highest-and-best-use considerations where relevant

Location Is One of the Biggest Valuation Factors

In Istanbul, location can change property value significantly within a very short distance.

Two apartments may both be located in:

Şişli

but one may be:

• 200 meters from metro

• On a quiet residential street

• Close to offices and shopping

while the other may be:

• Farther from public transport

• On a noisy arterial road

• In a weaker micro-location

The district name alone is therefore insufficient.

Professional valuation considers the actual property location.

Micro-Location Matters More Than Many Foreign Buyers Expect

For example:

Kadıköy

is not one uniform market.

An apartment's value can vary based on:

• Neighborhood

• Street

• Distance from Marmaray

• Metro access

• Ferry access

• Sea proximity

• View

• Building quality

Therefore:

District Average ≠ Individual Property Value

The same applies throughout Istanbul.

Floor Can Affect Value

In a modern residential tower, an apartment on:

Floor 25

with an unobstructed Bosphorus or city view may command a substantial premium over a similar unit on:

Floor 3.

But in an older low-rise building without an elevator, higher floors may sometimes be less attractive.

Therefore:

higher floor ≠ automatically higher value

without considering the building and local market.

View Can Affect Value

Views can create significant pricing differences.

Examples include:

• Bosphorus view

• Sea view

• Forest view

• City skyline

• Internal courtyard

• Building-facing view

But buyers should distinguish:

Permanent / Protected View

from:

Current View

A new development may eventually block an existing open view.

A valuation should consider the market evidence available at the valuation date rather than relying solely on marketing language.

Net Area vs Gross Area

One of the biggest foreign-buyer pricing mistakes involves square meters.

A developer may advertise:

150 m²

but that may represent a gross measure that includes different elements depending on the project.

The buyer should distinguish among relevant concepts such as:

• Net usable area

• Gross area

• Saleable area

• Common-area allocation

Two apartments advertised as:

150 m²

may provide very different actual internal living space.

Therefore:

Price Per Advertised m²

can be misleading if the area definitions are inconsistent.

Example: Gross Area Distortion

Apartment A

Advertised:

150 m²

Actual internal usable area:

112 m²

Price:

$300,000

Apartment B

Advertised:

135 m²

Actual internal usable area:

115 m²

Price:

$290,000

Apartment B appears smaller from the marketing headline.

But it may actually provide more usable interior space.

This is why serious valuation requires more than comparing brochure square-meter figures.

Building Age Matters

Building age can influence:

• Physical depreciation

• Maintenance

• Building systems

• Buyer demand

• Earthquake perception

• Renovation requirements

However:

Newer does not automatically mean more valuable.

An older apartment in:

• Nişantaşı

• Kadıköy

• Beşiktaş

may command a much higher price than a new apartment in a weaker location.

Property value reflects multiple variables simultaneously.

Building Quality Matters

Two buildings constructed in the same year can have very different values.

Relevant factors may include:

• Construction quality

• Lobby and common areas

• Elevator

• Parking

• Security

• Facilities

• Maintenance

• Management

• Aidat

This is why valuers do not simply use:

building year + square meters

to determine property value.

Legal Status Can Affect Value

A property with clear:

• Tapu

• Independent section

• Kat Mülkiyeti

• Building documentation

can be easier for the market to understand than a property with complicated or uncertain legal characteristics.

Likewise, issues involving:

• Hisseli ownership

• Mortgage

• Restrictions

• Project mismatch

• Unusual building history

may influence marketability and therefore valuation analysis.

This is why the valuation process intersects with the due-diligence topics covered in our separate Tapu and İskan guides.

Valuation Is Not the Same as Legal Due Diligence

This distinction is essential.

A valuation report may examine legal characteristics because they can affect value.

But buyers should not assume:

“An appraisal exists, therefore my legal due diligence is complete.”

The separate Tapu investigation should still verify matters such as:

• Owner

• Independent section

• Mortgage

• Haciz

• Şerh

• Ownership structure

Therefore:

Valuation Review ≠ Full Title Due DiligenceValuation Is Not the Same as İskan Due Diligence

Likewise, a valuation report should not be used as a substitute for checking:

• Yapı Ruhsatı

• İskan

• Approved architectural project

• Building history

These can affect valuation.

But building-document due diligence remains a separate buyer responsibility.

A useful formula is:

Tapu Check

• İskan Check

• Valuation Check

rather than treating one document as a substitute for the others.

Valuation Is Not an Earthquake-Safety Report

This distinction is equally important.

A property appraisal is not:

• Structural engineering report

• Concrete test

• Earthquake-performance analysis

• Foundation inspection

A valuer may consider building characteristics that influence market value.

That does not mean the property has undergone a detailed structural seismic assessment.

Therefore:

Valuation Report ≠ Earthquake Safety Certificate

Foreign buyers concerned about seismic safety should perform the separate technical due diligence discussed in our Earthquake-Safe Apartments in Istanbul guide.

Valuation Is Not an Investment Guarantee

Suppose a report values an apartment at:

$300,000

This does not mean:

“The apartment will be worth $400,000 in three years.”

A professional valuation is tied to:

• A particular property

• Market information

• A valuation date

If market conditions change after the valuation date, the property's later value may be different.

Therefore:

Current Valuation ≠ Future Return GuaranteeValuation Date Matters

Real-estate valuation is time-sensitive.

Imagine an appraisal conducted in:

January 2025

and the buyer wants to rely on it in:

August 2026.

Market conditions may have changed considerably.

Factors may include:

• Inflation

• TRY exchange rate

• Interest rates

• Housing supply

• Local demand

• Project completion

• New transport infrastructure

A valuation should therefore always be read together with its:

Valuation DateWho Prepares Property Valuation Reports in Turkey?

Professional real-estate valuation in Türkiye operates within a regulated professional framework.

SPK maintains information concerning authorized:

Gayrimenkul Değerleme Kuruluşları

or:

Real Estate Valuation Companies

Professional valuation involves licensed experts and organizations operating within the applicable regulatory framework.

This is important because:

An estate agent's price opinion is not the same thing as a formal professional valuation report.

Agent Price Opinion vs Professional Valuation

A real-estate agent can provide useful market knowledge.

A strong agent may know:

• Recent transactions

• Seller expectations

• Rental demand

• Negotiation levels

But that commercial opinion should not automatically be described as an:

official Ekspertiz report.

Professional valuation operates under a different framework.

Developer “Valuation” vs Independent Valuation

Another common problem occurs when a developer says:

“Our company values this apartment at $450,000.”

That figure may represent:

• Developer sales price

• Internal price list

• Marketing price

It does not automatically represent independent professional appraisal.

Foreign buyers should distinguish:

Developer Price List

from:

Independent Property ValuationCan the Seller Choose Any Number as the Market Value?

A seller can ask a commercially negotiated price.

But they cannot make that asking price become an independent market valuation merely by writing it in a brochure.

For example:

Developer Price

$500,000

Independent Market Evidence

Comparable apartments:

350,000–350,000–390,000

The developer can still ask $500,000.

The buyer must decide whether the premium is justified.

Three Common Valuation Approaches

Professional valuation can use different methods depending on the property and purpose.

For ordinary residential apartments, one of the most intuitive approaches is market comparison.

Other situations can also involve:

• Income-based analysis

• Cost-based analysis

The appropriate methodology depends on the asset.

Comparable Sales / Market Approach

The valuer examines comparable real estate in the relevant market.

Possible variables include:

• Location

• Building

• Floor

• Size

• Age

• View

• Condition

• Parking

• Facilities

Then adjustments may be considered.

Example

Subject apartment:

120 m² 2+1

Comparable 1:

125 m² — $310,000

Comparable 2:

118 m² — $295,000

Comparable 3:

122 m² — $305,000

The valuer does not necessarily calculate:

simple average = final value.

Adjustments may be required because one apartment may have:

• Better view

• Higher floor

• Better renovation

• Parking

than another.

Income Approach

For income-producing real estate, valuation can consider the income the asset is capable of generating.

For example:

Annual Net Income

$18,000

The relevant yield or capitalization assumptions can help estimate investment value.

This may be particularly relevant for:

• Commercial property

• Rental-focused assets

But residential investment analysis should still consider the actual local rental market.

Cost Approach

In certain cases, valuation can also consider:

• Land value

• Construction or replacement cost

• Depreciation

This approach can be relevant where market comparables are limited or the property has unusual characteristics.

Different methods may then be reconciled as appropriate.

Why Comparable Listings Alone Can Be Misleading

Suppose ten apartments are listed between:

300,000and300,000and400,000.

That does not prove properties are actually selling at those prices.

Listings show:

seller expectations.

Completed transactions provide different evidence.

Foreign buyers who compare only online asking prices may systematically overestimate the market.

“Everybody in This Project Asks $400K”

This is a common sales argument.

But perhaps:

• Units have been listed for 12 months

• Actual transactions close at $330K

• Sellers are anchoring high prices

Therefore:

Asking-price consensus is not necessarily transaction-price consensus.

What Is Emlak Rayiç Değeri?

Foreign buyers frequently encounter another value:

Emlak Rayiç Değeri

or, more precisely in many official contexts:

Emlak Vergisi Değeri

This relates to the municipal and property-tax system.

It should not automatically be confused with independent market valuation.

The property-tax value is calculated within a statutory municipal/tax framework rather than through the same process as an independent professional market appraisal.

Therefore:

Municipal Tax Value ≠ Professional Market AppraisalWhy Emlak Vergisi Value Can Differ From Market Value

Consider an Istanbul apartment.

Actual Market Transaction

15,000,000 TRY

Municipal Property-Tax Value

5,000,000 TRY

These numbers can serve different legal purposes.

The lower municipal number should not be interpreted as:

“The apartment's real market value is only 5 million TRY.”

Likewise, the fact that a seller asks 15 million TRY does not independently prove the property is worth 15 million.

Different valuation systems answer different questions.

Emlak Rayiç vs Market Value

A simplified comparison:

Tapu Sale Amount vs Market Value

Another important number appears in the property-transfer process.

The buyer and seller declare the transaction value used in the Tapu transfer.

Under the Turkish property-transfer framework, the real purchase and sale amount should be declared, while the declared amount cannot fall below the applicable Emlak Vergisi value.

This creates an important distinction:

Tapu Declared Transaction Amount

is not conceptually the same thing as:

Independent Professional ValuationDo Not Artificially Understate the Sale Price

Historically, some property-market participants declared low figures in order to reduce Tapu fees.

That is risky.

The correct framework requires the actual purchase/sale amount to be declared, subject to the statutory minimum linked to the Emlak Vergisi value.

Therefore:

Municipal Value Is a Minimum Reference for the Fee Framework — Not Permission to Declare an Artificially Low Price.

Example: Tapu Amount

Actual agreed price:

14,000,000 TRY

Municipal Emlak Vergisi value:

4,500,000 TRY

It would be incorrect to conclude:

“We can simply declare 4.5 million because that is the municipal value.”

The real transaction amount remains relevant to the official transfer.

Tapu Amount vs Asking Price

Suppose:

Seller Originally Asked

16,000,000 TRY

Negotiated Real Purchase Price

14,000,000 TRY

Tapu Transaction

The relevant real transaction amount is:

14,000,000 TRY

The original asking price has no reason to become the transaction amount once the parties have genuinely negotiated a lower sale price.

Again:

Asking Price ≠ Actual Sale PriceMarket Value vs Actual Sale Price

A property can sell below market value.

For example:

Estimated Market Value

15,000,000 TRY

Actual Transaction

13,000,000 TRY

Possible reasons:

• Seller needs cash quickly

• Family transaction

• Property needs renovation

• Buyer has strong negotiating position

Conversely, an apartment can sell above estimated market value if a buyer is willing to pay a premium.

Therefore:

Market value is an analytical estimate; sale price is an actual commercial outcome.

Six Different Values Foreign Buyers Should Know

At this stage, we can distinguish at least six important figures.

1. Asking Price

What the seller wants.

2. Negotiated Purchase Price

What buyer and seller actually agree.

3. Market / Appraisal Value

Professional estimate of property value.

4. Emlak Vergisi / Municipal Value

Tax-related statutory property value.

5. Tapu Transaction Amount

The real declared acquisition/sale amount used within the official transfer and fee framework.

6. Citizenship / Special Regulatory Value

A separate concept where a transaction is being used for a regulated objective such as Turkish citizenship.

The citizenship-specific valuation and TTB framework will be explained in Part 2.

The Most Important Value Comparison

The last two become central in Parts 2 and 3.

Why Foreign Buyers Confuse These Values

Real-estate marketing sometimes compresses all of them into one claim:

“The official value is $400,000.”

But that statement is incomplete.

A professional buyer should ask:

Which official value?

Do they mean:

• Tapu transaction amount?

• Valuation report?

• DAB?

• Citizenship TTB?

• Municipal value?

These are not interchangeable.

Example: “Official Value Is $450K”

Imagine a salesperson says:

“This apartment is officially valued at $450,000.”

Ask:

Question 1

Which document shows $450,000?

Question 2

When was the document prepared?

Question 3

Who prepared it?

Question 4

For what legal purpose?

Question 5

Is it a valuation report, a TTB, or simply a developer price sheet?

The answer can completely change the meaning of the claim.

Is a Valuation Report Required for Every Foreign Buyer?

This requires careful treatment because older online articles often give outdated blanket answers.

Türkiye's foreign-buyer valuation rules have changed over time.

The relevant TKGM framework distinguishes transactions according to:

• Whether the foreign person is the buyer

• The type of Land Registry transaction

• The specific regulatory purpose

Therefore, a current article should not simply repeat old claims such as:

“Every transaction involving any foreigner always requires an appraisal.”

The exact requirement depends on the current transaction scope.

Part 2 examines this in detail.

Why Older Foreign-Buyer Guides Can Be Misleading

Rules concerning foreign-buyer valuation have changed over time.

This is an excellent example of why:

Property due diligence should rely on current official rules rather than an old blog or an outdated checklist.

When a valuation report is required for a transaction, the buyer should confirm the current requirement through the applicable:

• Web Tapu process

• Tapu Müdürlüğü procedure

• Current TKGM guidance

Does a Valuation Report Protect You From Overpaying?

It can help.

But it does not eliminate all pricing risk.

Suppose:

Independent Valuation

$300,000

Seller Asking

$380,000

That discrepancy should trigger questions.

Perhaps the seller has:

• Overpriced the apartment

• Included furniture

• Assigned a view premium

• Targeted citizenship buyers

The buyer can use the valuation as negotiating evidence.

But the Valuation Is Still an Estimate

A valuation is a professional opinion based on:

• Information available

• Methodology

• Market evidence

• Valuation date

It is not an exact scientific measurement.

Two competent valuers can potentially reach somewhat different conclusions.

That does not necessarily mean one is fraudulent.

Real-estate valuation involves professional judgment.

What If the Report Seems Too High?

A foreign buyer should not automatically celebrate a very high appraisal.

Ask whether:

• Comparable properties support it

• Property size is correct

• Legal characteristics are correct

• View and floor assumptions are reasonable

• Recent market evidence supports it

A high valuation can be just as important to scrutinize as a low valuation.

What If the Report Seems Too Low?

Likewise, a low report should trigger investigation.

Potential explanations include:

• Asking price is too high

• Poor comparable data

• Legal problem

• Different area calculation

• Weak location

• Physical condition

• Market movement

The buyer should understand the reason before deciding.

Can You Challenge or Correct a Valuation Report?

The official valuation system provides procedures for dealing with genuine errors or missing information.

Potential factual problems may include:

• Wrong floor

• Wrong independent section

• Incorrect area

• Wrong property characteristics

A correction process is different from simply demanding a higher number because the buyer wants citizenship eligibility.

You Cannot Legitimately “Order” the Desired Value

A buyer should be cautious if someone says:

“Tell me what value you need and I will get the report.”

A professional valuation should be independent.

The purpose is to estimate value.

Not to reverse-engineer a predetermined number.

Independent Valuation vs Sales Incentive

There is a natural conflict when:

the person earning commission from the sale

also tells you:

what the apartment is worth.

That does not mean every agent is unreliable.

But it explains why independent valuation can add value to the buyer's decision.

Valuation Company vs Individual Expert

Formal valuation can involve:

• Authorized valuation organization

• Licensed valuation professionals

• Responsible reviewers

This is different from asking an informal property consultant for an opinion.

Can You Check Authorized Valuation Companies?

Yes.

SPK maintains official information regarding authorized:

Gayrimenkul Değerleme Kuruluşları

For official transactions, however, buyers should also follow the specific ordering and assignment procedure applicable to the relevant transaction.

Do not independently commission any report and assume it will automatically be accepted for:

• Tapu

• Citizenship

• Another regulated process

Citizenship Valuation Uses a Special System

This deserves an early warning even though Part 2 examines it in detail.

A normal market valuation and the current Turkish citizenship property-value verification system should not be treated as the same process.

Citizenship-related valuation follows a specialized official workflow involving:

Web Tapu

and:

GEDAŞ

under the current TKGM framework.

Therefore:

A developer's private appraisal should never automatically be assumed to satisfy a citizenship application.

What Is GEDAŞ?

For now, the important point is that GEDAŞ forms part of the official property-valuation workflow used for current citizenship-related valuation requests.

The detailed:

• GEDAŞ process

• Web Tapu application

• TTB

• Citizenship value calculation

is covered in Part 2.

Market Valuation and Citizenship Valuation Answer Different Questions

This distinction is fundamental.

Normal Buyer Question

What is this apartment reasonably worth?

Citizenship Question

Does the transaction satisfy the current official investment-value framework for citizenship?

They overlap.

But they are not identical.

Example: $450,000 Advertisement

A developer markets an apartment as:

$450,000 Citizenship Eligible

A foreign buyer should not interpret the advertisement as final evidence.

The buyer must distinguish:

• Developer asking price

• Actual agreed price

• Professional valuation

• Official transaction amount

• Payment documentation

• Citizenship TTB/value determination

Part 2 explains why a $450,000 listing can still require further analysis before citizenship eligibility is established.

Valuation and Property Residence Permit

Property-based residence is also a separate system.

The immigration rules concerning the qualifying property's value and residential characteristics are not simply replaced by a seller's valuation.

Therefore:

A private market appraisal does not by itself grant a Turkish residence permit.

Residence eligibility should be analyzed separately under the current Migration Management requirements.

Valuation and Property Taxes

A professional appraisal is also different from the values used for:

• Emlak Vergisi

• Tapu Harcı

• Valuable Housing Tax

Each tax has its own statutory framework.

Foreign buyers should therefore avoid assuming:

“My appraisal says 500,000,thereforeeveryTurkishpropertytaxwillbebasedon500,000,thereforeeveryTurkishpropertytaxwillbebasedon500,000.”

That does not follow automatically.

Tax rules must be checked separately.

Valuation and Tapu Harcı

For an ordinary property transfer, Tapu Harcı is calculated under its own statutory framework based on the declared real transaction value, subject to the applicable minimum linked to the Emlak Vergisi value.

This rule operates separately from the concept of professional market appraisal.

Therefore:

Professional Valuation ≠ Automatic Tapu Harcı BaseExample: Four Different Values on One Apartment

Consider an Istanbul apartment.

Seller Asking Price

16,000,000 TRY

Agreed Purchase Price

14,500,000 TRY

Professional Valuation

14,000,000 TRY

Municipal Emlak Vergisi Value

5,000,000 TRY

All four numbers can potentially exist simultaneously.

They answer different questions.

Which One Is the “Real” Value?

That depends on what question you are asking.

What does the seller want?

16M

What will the buyer actually pay?

14.5M

What does independent valuation estimate?

14M

What is the tax-framework municipal value?

5M

Therefore:

The phrase “official property value” is too vague to use without defining the underlying document and purpose.

The Seven-Value Framework for Foreign Buyers

For the remainder of this guide, use this framework.

Value 1 — Asking Price

Marketing number.

Value 2 — Negotiated Sale Price

Actual commercial agreement.

Value 3 — Professional Market Valuation

Independent appraisal estimate.

Value 4 — Emlak Vergisi Value

Municipal/statutory tax reference.

Value 5 — Tapu Transaction Amount

Officially declared real transfer value.

Value 6 — DAB Amount

Foreign-exchange conversion documentation associated with the foreign-buyer transaction.

Value 7 — TTB / Citizenship Investment Value

Specialized value determination used in the current citizenship-investment framework.

The final two become central in Part 2.

Common Property Valuation Mistakes

Treating Asking Price as Market Value

A seller's expectation is not an independent valuation.

Treating Developer Price as Official Value

A developer's price list is a commercial document.

Treating Emlak Rayiç as Market Price

Municipal/tax value serves a different statutory purpose.

Treating Tapu Amount as an Appraisal

The official transaction amount is not itself an independent valuation report.

Declaring an Artificially Low Tapu Amount

The real transaction amount should be declared under the applicable property-transfer rules.

Treating an Appraisal as Structural Due Diligence

It is not an earthquake-performance report.

Treating an Appraisal as Clean-Title Certification

Separate Tapu due diligence is still required.

Treating a High Appraisal as Guaranteed Future Appreciation

Valuation is date-specific and markets change.

Using an Old Foreign-Buyer Article

Foreign-buyer valuation rules have changed over time.

Use current official guidance.

Assuming Any Valuation Report Works for Citizenship

Current citizenship valuation follows a specialized official process.

Preliminary Property Valuation Checklist

Before buying, ask:

Price

• What is the asking price?

• What is the realistic negotiated price?

• What comparable properties support that figure?

Property

• Is the correct independent section identified?

• Is the correct size confirmed?

• Are net and gross area understood?

• Are floor and orientation confirmed?

• Has the building age been checked?

Legal

• Has Tapu status been checked?

• Have İskan and building documentation been reviewed?

• Are restrictions relevant to value understood?

Valuation

• Is a formal report required for this transaction?

• Who prepared or will prepare it?

• What is its valuation date?

• What purpose was it prepared for?

Citizenship

Where applicable:

• Is this the correct official citizenship valuation process?

• Is the report through the current Web Tapu/GEDAŞ framework?

• Has the seller confused asking price with citizenship value?

Questions to Ask When Someone Shows You an Appraisal

Do not look only at the final number.

Ask:

What Property Was Valued?

Verify the independent section.

What Date?

Market conditions change.

What Purpose?

Was it prepared for:

• Bank loan?

• Purchase?

• Citizenship?

• Another purpose?

Who Prepared It?

Verify the professional framework.

What Assumptions Were Used?

Especially:

• Size

• Legal status

• Condition

Which Comparables Were Considered?

Do they genuinely resemble the subject property?

A Better Price-Analysis Formula

Instead of:

Seller Price = Property Value

use:

Property Characteristics

• Legal Status

• Physical Condition

• Location

• Comparable Market Evidence

• Professional Analysis
  = Better Valuation Benchmark

Then compare that benchmark with the seller's price.

Buyer Example: Is $320,000 Reasonable?

Suppose a foreign buyer finds:

2+1 apartment in Kağıthane

Seller asks:

$320,000

The buyer should investigate:

Comparable Properties

Similar units sell around:

270,000–270,000–295,000

Unit Difference

Subject apartment has:

• Better view

• Higher floor

• Furniture

Potential premium:

15,000–15,000–20,000

An analytically supported value might therefore be closer to:

290,000–290,000–310,000

rather than automatically accepting $320,000.

The exact figure requires actual market evidence.

But this illustrates the reasoning process.

Buyer Example: Cheap Property

Another property is advertised for:

$230,000

while similar properties are approximately:

$280,000.

The buyer should not immediately conclude:

“Great deal.”

Ask:

• Does it have a mortgage?

• Is it Hisseli?

• Is İskan missing?

• Is there a structural concern?

• Is the unit different from the approved project?

• Does the seller need urgent cash?

A low price can be:

opportunity

or:

risk signal.

Valuation Is a Due-Diligence Tool, Not a Substitute for Judgment

The strongest buyer uses valuation as part of a broader system:

Market Analysis

• Valuation

• Tapu Due Diligence

• İskan Due Diligence

• Technical Due Diligence

• Financial Analysis

A report should improve the buyer's decision.

It should not replace the buyer's decision.

Key Takeaways

A property valuation report in Türkiye is fundamentally different from a developer's price list or seller's asking price.

Professional valuation aims to estimate the probable value of real estate at a specific date through an independent and professional process.

Foreign buyers should distinguish at least the following concepts:

Asking Price

Seller's requested amount.

Negotiated Sale Price

Actual commercial agreement.

Professional Valuation

Independent estimate of property value.

Emlak Vergisi Value

Statutory municipal/property-tax value.

Tapu Transaction Amount

The real acquisition/sale amount declared within the transfer framework.

DAB Amount

Foreign-exchange conversion documentation.

TTB / Citizenship Value

Separate specialized investment-value determination for citizenship purposes.

These values can be different.

Another important 2026 lesson is that foreign-buyer valuation requirements have changed over time.

That means old articles saying:

“Every transaction involving any foreigner always requires an appraisal.”

should not automatically be relied upon.

The exact requirement should be checked under the current transaction-specific TKGM process.

Citizenship property valuation also follows a specialized official framework involving:

Web Tapu → GEDAŞ

and the citizenship-specific TTB process.

That system is the main focus of Part 2.

The central rule from Part 1 is:

A property's asking price, market value, municipal value, Tapu transaction amount and regulatory investment value are different concepts. Always identify which value is being discussed before relying on the number.

The strongest buyer therefore uses:

Independent Valuation + Market Comparison + Legal Due Diligence + Building Due Diligence

rather than relying on:

Seller Price Alone

Is a Property Valuation Report Required for Foreign Buyers in Turkey in 2026?

One of the most confusing questions for foreign property buyers is:

“Do foreigners still need an Ekspertiz / property valuation report to buy real estate in Turkey?”

The answer requires more precision than a simple yes or no.

Türkiye's valuation-report rules have changed over time.

Under the amended TKGM framework, the requirement is no longer expressed as a blanket rule covering every transaction merely because a foreign person appears on either side.

TKGM states that valuation reports under the 2019/1 framework are required where:

• A foreign natural person is the buyer

• The transaction falls within the transaction categories specified by the relevant rule

The earlier broader rule that also covered situations where the foreigner was only the seller was narrowed.

Therefore:

Foreign Seller Alone ≠ Automatic Valuation Requirement

and:

Foreign Buyer → Check the Current Transaction-Specific Valuation Rule

For a typical foreign individual purchasing an Istanbul apartment, valuation requirements are therefore highly relevant, but the exact legal requirement should be confirmed against the particular transaction rather than an old online checklist.

Why Older Articles About Foreign Buyer Valuation Are Often Wrong

Older guides frequently state:

“Every property transaction involving a foreigner requires a valuation report.”

That reflected an earlier formulation of the TKGM regime.

The amended 2019/1 framework specifically changed the rule so that valuation reports would be requested where the foreign natural person is the buyer and the transaction is within the relevant listed categories.

This is a good example of why foreign buyers should distinguish:

Historical Rule

from:

Current Transaction Rule

A blog written in 2019 or 2020 may still rank highly in Google while describing a procedure that has since changed.

Some Transactions Have Separate Treatment or Exemptions

The TKGM framework also contains transaction categories where a valuation report is not requested under the ordinary foreign-buyer rule.

This is why the correct question is not:

“Am I foreign?”

It is:

“What exact Land Registry transaction am I conducting, and does the current TKGM transaction list require a valuation report for it?”

For an ordinary market purchase from a private seller, valuation should be considered part of the foreign-buyer transaction workflow unless the specific official procedure confirms otherwise.

TKGM FAQ vs the Detailed Circular

Foreign buyers may notice that some TKGM FAQ pages use broader wording and state that a valuation report is among the documents required when a foreign person is involved in a property sale.

At the same time, TKGM's more detailed amended 2019/1 rule specifies that the mandatory framework applies where the foreign natural person is the buyer and the transaction is one of the listed transaction types.

For a real transaction, the safer approach is therefore:

Use the current Web Tapu / Tapu Müdürlüğü transaction requirements for the exact application rather than relying on one generalized FAQ sentence.

How Is an Official Valuation Report Requested?

Formal valuation reports intended for relevant TKGM transactions are integrated into:

Web Tapu + TADEBİS

The 2024/2 TKGM Circular states that valuation applications for natural-person-owned properties are made by the property owner through the official Web Tapu system.

For Turkish citizen owners, ALO 181 can also be used in the circumstances specified by TKGM.

This means the official workflow is not:

Buyer calls a random valuer → gets PDF → uploads it to Tapu.

Instead, the formal process is integrated with the government valuation system.

Who Applies Before the Property Is Sold?

This is an important practical detail.

Before the sale, the apartment still belongs to the seller.

The 2024/2 Circular states that the valuation request for a natural-person-owned property is submitted by the:

taşınmaz maliki — property owner

through Web Tapu.

Therefore, in a normal resale transaction, seller cooperation can be necessary for the official valuation workflow.

Foreign buyers should discuss this before reaching the closing date.

Foreign Owners Can Access Web Tapu

TKGM provides a dedicated:

FOR FOREIGNER

portal within Web Tapu.

Foreign natural-person property owners can use that route for relevant services, including valuation-report applications under the current Web Tapu framework.

This reduces the need for unofficial intermediaries to control the valuation process.

Step-by-Step Valuation Application Process

The official process broadly follows this structure:

Step 1 — Enter Web Tapu

The property owner enters through the appropriate Web Tapu portal.

Step 2 — Select the Valuation Request

The appropriate transaction purpose is selected.

Step 3 — Identify the Property

The valuation request is connected to the registered real estate.

Step 4 — Choose the Correct Purpose

This distinction is critical:

Ordinary Transaction

Select the normal:

Satış — Sale

valuation purpose.

Citizenship Transaction

Select:

Vatandaşlığa Konu Satış

and use the citizenship-specific GEDAŞ route.

Ordinary Valuation vs Citizenship Valuation

This is where the 2026 system divides into two different paths.

Ordinary / Non-Citizenship Valuation

For a valuation that is not being used for Turkish citizenship, TKGM's 2024/2 framework allows the relevant valuation company to be selected:

• From the available authorized list

• Through the automatic algorithm

Citizenship Valuation

For a transaction intended to support exceptional Turkish citizenship through property investment:

GEDAŞ Gayrimenkul Değerleme A.Ş.

must be selected through the designated citizenship request path.

This distinction is fundamental.

Can You Commission Any Private Appraisal and Use It at Tapu?

Not for an official transaction where the TKGM valuation system applies.

The 2024/2 Circular states that reports prepared outside the prescribed:

• Web Tapu

• ALO 181 where applicable

• TADEBİS

process and outside the required format and standards are not accepted for those Land Registry transactions.

Therefore:

Private Appraisal for Your Own Investment Analysis ≠ Automatically Valid Official TKGM Report

You can commission independent analysis for your own decision-making.

But do not assume it can replace the officially generated report required for the Land Registry or citizenship process.

Who Prepares the Valuation?

Türkiye has a regulated real-estate valuation profession.

SPK maintains official information and lists concerning:

Gayrimenkul Değerleme Kuruluşları

or authorized real-estate valuation organizations.

SPK's regulatory framework includes requirements involving:

• Corporate structure

• Licensed professional staff

• Independence

• Professional conduct

• Valuation standards

An estate agent's price estimate is therefore fundamentally different from a formal professional valuation.

How Is the Valuation Company Selected?

For non-citizenship transactions under the 2024/2 framework, the Web Tapu process can allow:

Preferred Selection

A valuation company can be selected from the eligible list.

or:

Automatic Assignment

The system can use its assignment algorithm.

For citizenship-related valuation:

Select GEDAŞ

through the specific citizenship transaction purpose.

What Happens After the Application?

TKGM's 2024/2 procedure describes the next stages.

After the application procedure is completed:

1. The applicant receives information about the valuation fee and payment period.

2. The applicant receives a request/reference number.

3. If the fee is not paid within the specified period, the request is cancelled.

4. After payment, the valuation request is transmitted through TADEBİS.

5. The authorized valuation organization assigns a professional to prepare the report.

This means the assignment occurs after the required valuation service payment is completed.

Can the Applicant Cancel the Valuation Request?

Before the service fee is paid, the applicant can cancel the valuation request through Web Tapu under the procedure described by TKGM.

After payment, the process moves into the valuation assignment stage through TADEBİS.

How Long Can a Normal Tapu Valuation Report Be Used?

The 2024/2 Circular states that valuation reports used in Tapu transactions under that framework have a:

3-Month Use Period

If that period expires before the Land Registry transaction, a new report must be requested through the system.

There is now a separate validity framework for the newer citizenship-specific TTB documents issued after December 9, 2024.

We will examine that distinction in Part 3.

What If the Valuation Report Contains an Error?

The official system also includes mechanisms for correcting errors or omissions.

TKGM states that a correction-request procedure was integrated into the valuation system for circumstances where mistakes or missing information are identified in a report.

Potential factual problems might include:

• Wrong floor

• Incorrect independent-section information

• Incorrect area

• Property-characteristic error

The purpose of correction is to fix a genuine factual or reporting problem.

It is not a legitimate method for saying:

“The value is too low for citizenship, please increase it.”

Control Valuation Reports

The 2024/2 framework also defines the concept of a:

Kontrol Değerleme Raporu

A control valuation can be requested where there are concerns regarding:

• The assigned value

• Factors affecting the value

• Differences between valuation conclusions

and TKGM can arrange another authorized valuation through TADEBİS for comparison and control purposes.

This adds another layer of oversight to the formal system.

The Special Citizenship Valuation System

Turkish citizenship by property investment requires a much more specific valuation process.

The current real-estate investment threshold remains:

USD 400,000

or its qualifying foreign-currency equivalent under the applicable framework, together with the required three-year restriction on transfer.

But:

A property being advertised for $400,000 or more does not prove that the transaction satisfies the citizenship investment rules.

The current citizenship framework uses several separate value and payment checks.

Why Citizenship Valuation Changed

In March 2024, TKGM issued the 2024/2 Circular governing real-estate valuation procedures.

The circular introduced an important citizenship-specific rule:

For citizenship-related sale applications, the valuation request must use:

GEDAŞ Gayrimenkul Değerleme A.Ş.

through the designated Web Tapu citizenship-sale process.

The circular further states that for sales or sale promises made after the circular became effective, subsequent citizenship requests will accept only valuation reports prepared through the GEDAŞ route.

What Is GEDAŞ?

For a foreign property investor, the practical role of GEDAŞ is straightforward:

It forms the required official valuation route for current property-based citizenship applications under the TKGM framework.

The applicant does not simply choose whichever private appraisal offers the desired value.

The citizenship request must follow:

Web Tapu → Citizenship Sale Purpose → GEDAŞ

under the current system.

Citizenship Valuation Is Not Just an Ekspertiz Report Anymore

Another major change took effect on:

December 9, 2024

TKGM's updated 2024/4 Citizenship Circular and Guide introduced the current investment-amount verification framework involving:

TTB

or:

Taşınmaz Edinim Sureti ile Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi

The current TKGM citizenship document library lists both:

• The 2024/4 Citizenship Circular

• TTB sample

• 2024/4 implementation guide

as the current official materials for property-based citizenship transactions.

What Is TTB?

TTB can be translated approximately as:

Property-Acquisition Citizenship Investment Amount Determination Document

Its purpose is to determine the amount of a property investment that can be recognized under the citizenship framework.

The official TTB sample states that it is prepared:

• Under TKGM's 2024/4 Circular

• As an attachment to the relevant valuation report

• Through the TADEBİS system

Therefore:

TTB ≠ Ordinary Tapu Valuation Report

but:

TTB Is Built Into the Current Citizenship Valuation/Verification FrameworkTTB vs Ekspertiz Report

The difference can be simplified as follows:

Citizenship buyers should never use these terms interchangeably.

What Does the TTB Say?

For a citizenship application based on a single property, the current TKGM guide states that the TTB must contain the determination that the property:

meets the minimum investment amount required under the citizenship regulation.

When that determination exists, the Tapu Müdürlüğü uses the TTB directly for the relevant process.

This means a TTB is not simply a document saying:

“Market value: X.”

It contains a citizenship-specific investment determination.

Why a $450,000 Listing Can Still Fail Citizenship

Consider:

Developer Asking Price

$450,000

The marketing material says:

“Citizenship Eligible.”

That statement alone proves nothing.

Under the current citizenship framework, the official process considers several distinct elements.

The current TKGM guide requires the relevant:

• Official deed / sale-promise amount

• Payment / transfer amount

to satisfy the applicable minimum investment threshold separately, while the investment is verified through the TTB framework.

Therefore:

Listing Price ≠ Citizenship QualificationThe Citizenship Value Test Is Multi-Layered

For the current USD 400,000 property route, think of four separate layers.

Layer 1 — Official Transaction Amount

The sale amount declared in the official deed—or qualifying sale-promise amount—must meet the relevant investment threshold.

Layer 2 — Actual Payment

The documented transfer/payment must separately satisfy the threshold.

Layer 3 — DAB

The foreign-exchange conversion documentation must support the qualifying transaction amount.

Layer 4 — TTB

The citizenship-specific investment amount determination must support the transaction.

A strong citizenship transaction therefore needs these components to align.

Citizenship Formula

A simplified conceptual formula is:

Qualifying TTB

• Sufficient Official Sale Amount

• Sufficient DAB

• Sufficient Bank Payment Evidence
  = Value Side of Citizenship Transaction

Other legal citizenship requirements still apply.

Example 1 — 450KListing,450KListing,390K Citizenship Value

Suppose:

Listing Price

$450,000

Agreed Price

$450,000

DAB

$450,000

TTB Recognized Investment Amount

$390,000

For a single-property transaction, the TTB would not support the current $400,000 minimum.

The fact that the seller advertised the apartment at:

$450,000

does not repair the shortfall.

This illustrates:

Marketing Price Cannot Override TTBExample 2 — TTB Above 400KbutDABBelow400KbutDABBelow400K

Suppose:

TTB Investment Amount

$430,000

DAB

$395,000

The current TKGM guide contains a specific rule:

If the USD amount shown in the TTB is greater than the DAB amount submitted for that property, only the amount up to the:

DAB

is taken into account.

Therefore, in this simplified example:

$395,000

rather than:

$430,000

would be relevant from this comparison.

The citizenship threshold would not be satisfied on that basis.

This Creates a Critical RuleTTB Cannot Rescue an Insufficient DAB

The investor must coordinate the currency-conversion process correctly before closing.

Example 3 — High Valuation, Low Actual Payment

Suppose:

TTB

$450,000

DAB

$450,000

Actual Bank Payment

$380,000

This is still problematic.

The current TKGM citizenship guide requires documentary proof that the required minimum amount has actually been paid to the seller or relevant recipient, and the payment amount is separately considered in the investment-value test.

Therefore:

A high appraisal does not replace an insufficient real payment.

Example 4 — All Main Amounts Above $400K

Consider:

TTB Investment Amount

$425,000

DAB

$420,000

Official Sale Amount

$420,000 equivalent

Qualifying Bank Payment

$420,000 equivalent

The value side of the transaction is much more coherent because each main threshold component independently remains above:

$400,000

subject of course to all other citizenship conditions.

What Is DAB?

DAB means:

Döviz Alım Belgesi

It is not a property valuation report.

Under the foreign-buyer property acquisition framework, the relevant foreign currency is sold through a Turkish bank for sale to the Central Bank mechanism, and the bank produces the DAB connected with the property transaction.

The current citizenship guide states that the DAB is sent by the bank to the relevant Tapu Müdürlüğü through KEP.

What Information Should the DAB Contain?

For the citizenship transaction, the current guide requires identifying information including:

• Name and surname of the person for whom the currency conversion is performed

• Passport or foreigner identification number

• Property number

• USD equivalent of the converted currency

• The relevant transaction-purpose statement

Where the property number is not available, identifying property information such as:

• Ada

• Parsel

• Block where applicable

• Independent-section number

must be included as specified by the current rule.

This is why a generic bank exchange receipt should not automatically be treated as a correctly prepared property DAB.

DAB vs Valuation Report

The functions are completely different.

DAB

Answers:

How much qualifying foreign currency was converted through the required banking process?

Valuation Report

Answers:

What is the property worth under the valuation framework?

TTB

Answers:

What amount is recognized in the citizenship investment determination?

Therefore:

DAB ≠ Ekspertiz ≠ TTBDAB Does Not Prove Market Value

Suppose a buyer converts:

$500,000

through the DAB process.

That does not prove the apartment has a market value of:

$500,000.

DAB documents currency conversion.

It is not an appraisal.

High Valuation Does Not Prove DAB Compliance

Likewise:

Valuation: $500,000

does not prove that:

$500,000 DAB

was properly completed.

The systems must be handled separately.

Which Amount Is Used in the Official Deed?

Under the current citizenship guide, the Tapu Müdürlüğü uses the Turkish-lira amount shown in the DAB when preparing the official deed for transactions under the DAB system.

The guide states that after introduction of the DAB procedure, a separate exchange-rate calculation based on the application date is not made for determining the relevant transaction amount; the DAB is used instead.

This makes proper DAB preparation particularly important before closing.

Can VAT and Fees Be Included in the Citizenship Property Amount?

Foreign investors need to distinguish:

property price

from:

transaction expenses.

The current TKGM guide states that the foreign-currency sale amount used as the declared property/sale-promise amount should not include non-property-price items such as:

• VAT

• Commission

• Expenses

• Tax

• Fees

Therefore, a developer should not simply say:

“Property 380K+VAT+commission+legalfees=morethan380K+VAT+commission+legalfees=morethan400K, so citizenship qualifies.”

That is not how the qualifying property amount should be calculated.

Example: 380KProperty+380KProperty+30K Costs

Suppose:

Property Price

$380,000

VAT + Commission + Other Costs

$30,000

Total Cash Outflow

$410,000

The investor should not assume:

“I spent $410,000, therefore I crossed the citizenship threshold.”

The citizenship investment requirement concerns the qualifying real-estate investment amount—not simply every dollar the buyer spends during the purchase.

Bank Payment Evidence

Citizenship transactions also require evidence that the qualifying purchase price has actually been paid.

The current TKGM guide requires an approved bank receipt showing payment of the applicable minimum amount to the:

• Property seller

• An appropriately connected relevant recipient under the circumstances specified by the guide

This payment evidence is separate from the DAB.

Why DAB and Bank Receipt Are Both Needed

The two documents answer different questions.

DAB

Shows the required currency-conversion process.

Bank Receipt

Shows transfer/payment of the property consideration.

Therefore:

Currency Converted ≠ Automatically Property Price Paid

and:

Payment Made ≠ Automatically Correct DAB Completed

The citizenship file requires the transaction trail to be coherent.

What Should the Bank Receipt Reference?

The current citizenship guide states that the payment receipt should contain the property information shown in the DAB or make reference to the relevant DAB transaction.

This helps connect:

Money

to:

Property

to:

Citizenship Transaction

Payment to Someone Other Than the Registered Seller

Transactions can sometimes involve legitimate payment recipients other than the seller's personal bank account.

The current TKGM guide allows Tapu officials to evaluate a reasonable relationship where funds are transferred to related persons such as:

• Authorized representative

• Spouse

• Construction-for-land-share right holder

• Mortgage creditor

• Attachment creditor

• Company owner

depending on the transaction structure.

But this is not permission to send money to any account chosen by the agent.

The legal relationship must make sense and be documented.

Do Not Pay a Citizenship Property Into an Unrelated Agent Account

A high-risk structure would be:

Buyer → Agent's personal account

with no clear documentary relationship to the seller or property.

The citizenship payment trail should be designed before funds are transferred, not reconstructed afterward.

Multiple Properties for Turkish Citizenship

A citizenship investor does not necessarily need to purchase one single $400,000 apartment.

The current TKGM citizenship guide states that for direct sale acquisitions, there is no fixed maximum number of properties.

The essential requirement is that the qualifying investment amount be reached.

Therefore, a buyer might potentially use:

Apartment A

$220,000 qualifying amount

Apartment B

$200,000 qualifying amount

=

$420,000

subject to the TTB, DAB, payment and all other requirements.

How Are Multiple Properties Evaluated Under TTB?

For multiple properties, the current guide states that the USD investment amounts shown in the citizenship-value section of the individual TTBs are added together.

However, if a property's TTB amount exceeds its DAB amount, only the DAB amount is counted for that property.

This creates a property-by-property cap.

Example: Two Properties

Property A

TTB:

$230,000

DAB:

$230,000

Counted:

$230,000

Property B

TTB:

$210,000

DAB:

$190,000

Counted:

$190,000

Total Recognized From This Comparison

230,000+230,000+190,000

=

$420,000

The second property's 210,000TTBdoesnotallow210,000TTBdoesnotallow210,000 to be counted because its DAB is only $190,000.

Another Multiple-Property Example

Property A

TTB/DAB-recognized amount:

$205,000

Property B

TTB/DAB-recognized amount:

$180,000

Total:

$385,000

Even if their combined listing prices were:

$450,000

the relevant value comparison would still fall below the $400,000 threshold.

Multiple Sale-Promise Contracts Are Different

The rules for:

direct completed purchases

and:

notarized sale-promise transactions

are not identical.

For direct purchase, the current guide does not impose a numerical limit on the number of properties used to reach the threshold.

For citizenship applications based on a sale promise, however, the required investment amount must be satisfied through:

One Sale-Promise Contract

That single contract can include multiple properties.

But the current guide states that multiple separate sale-promise contracts cannot be combined for the citizenship application.

Sale Promise Example

Acceptable structure in principle:

One Notarized Sale-Promise Contract

containing:

• Apartment 1

• Apartment 2

• Apartment 3

with the qualifying amount satisfied.

Not accepted under the current guide:

Contract A

$150,000

Contract B

$150,000

Contract C

$120,000

as three separate sale-promise contracts intended to be aggregated.

Can You Buy Some Properties and Complete the Rest With a Sale Promise?

The current citizenship guide states that where properties already acquired under the guide do not reach the required citizenship amount, the remaining shortfall cannot simply be completed using a sale-promise agreement.

This is another reason to structure the citizenship portfolio before purchasing.

Sale-Promise Payment Must Be Upfront

For a citizenship application based on a notarized sale-promise agreement, the current guide requires the qualifying amount to be:

Paid in Advance

and the amount must be paid no later than the date of the sale-promise contract.

Therefore:

Installments paid after the qualifying sale-promise date cannot simply be assumed to satisfy the citizenship rule.

Which Properties Can Be Used for a Citizenship Sale Promise?

The current TKGM guide states that citizenship applications based on notarized sale promises are valid for properties where:

• Kat Mülkiyeti

• Kat İrtifakı

has been established.

This is especially important for off-plan investors.

Off-Plan Does Not Mean “Any Future Apartment”

An investor cannot simply sign a private developer reservation agreement for an undefined future unit and assume it qualifies as a citizenship sale promise.

The legal structure of the property and contract matters.

The current official route requires the appropriate registered Kat Mülkiyeti / Kat İrtifakı structure for sale-promise citizenship applications.

Valuation of New-Build and Under-Construction Property

Formal valuation rules also address incomplete construction.

TKGM's 2024/2 valuation framework specifically includes detailed rules for:

natamam — incomplete / under-construction properties

where Kat İrtifakı has been established.

The valuer does not simply take the developer's future completed price at face value.

How Is an Under-Construction Property Evaluated?

For property still under construction, the valuation should consider matters including:

• Current value of comparable completed projects

• Costs associated with completion

• Identifiable completion risks

• Current construction stage

This means:

Developer Future Price ≠ Automatic Current Valuation

Construction Risk Can Reduce or Prevent a Valuation

TKGM's 2024/2 framework goes further.

For an incomplete property where there is substantial risk that:

• The project has been abandoned

• Construction will not continue

the valuation expert can decline to assign a normal property value and show the relevant value field as:

“hesaplanmadı” — not calculated.

This is a very important protection for foreign off-plan investors.

Building Permit Timing Also Matters

The 2024/2 valuation rules include checks tied to:

• Building permit date

• Whether construction actually started

• Construction stage

• Whether the permit needs renewal

For example, the framework states that in certain situations where too much time has elapsed since the permit and construction has not properly started or the permit requires renewal, a valuation may not be assigned under the ordinary framework.

This shows how valuation can expose off-plan project risk that a glossy brochure does not reveal.

Valuation and Approved Legal Area

Another important principle in the 2024/2 framework concerns areas that do not legally correspond with the approved project.

For unfinished properties, areas that are inconsistent with the architectural project and have not yet been constructed are not simply included in the independent section's gross area for valuation purposes.

This reinforces the connection between:

Valuation

and:

İskan / Project Due Diligence

Major Unpermitted Renovation Can Affect Valuation

TKGM's valuation framework also addresses substantial alterations.

For a physically completed property undergoing a major alteration, the necessary alteration permit should exist.

Where major alteration continues without the required permit, the framework states that a value is not assigned in the ordinary way.

This is why an apartment that looks larger or more luxurious after renovation may not automatically receive a higher legal-use valuation.

Example: Illegal-Looking Penthouse Extension

Seller advertises:

180 m² Penthouse

But approved legal configuration supports:

140 m²

with an additional:

40 m² enclosed terrace

that lacks proper project support.

A professional valuation cannot simply treat every physical square meter as equally legitimate.

Legal-use characteristics can materially affect the valuation.

New Build vs Resale Valuation

New Build

Valuation may pay particular attention to:

• Construction stage

• Building permit

• Kat İrtifakı

• Completion risk

• Comparable completed developments

Resale

Valuation may focus more heavily on:

• Existing physical condition

• Legal use

• Renovation

• Building age

• Comparable transactions

• Current marketability

Both require professional analysis.

Citizenship Valuation and Hisseli Ownership

The current citizenship guide states that a foreign applicant cannot qualify through acquiring a property in a way that creates shared ownership among multiple foreign buyers.

For example:

Foreigner A buys 50%

and:

Foreigner B buys 50%

of one apartment.

That property cannot simply be used independently by each buyer for the citizenship property route.

By contrast, a property previously owned by multiple persons can potentially be purchased in full by one foreign applicant.

This should be considered before valuation and closing expenses are incurred.

TTB Does Not Control Tapu Harcı Value by Itself

Another subtle but important distinction:

TKGM's current 2024/4 Circular states that the amount determined in a TTB does not itself have binding effect for Tapu Harcı purposes under the current fee legislation.

Therefore:

TTB ≠ Tapu Tax/Fee Base

This reinforces the central lesson of Article 17:

Different property values exist for different legal purposes.

Do Not Use TTB as Your Only Investment Valuation

A citizenship investor should also avoid the reverse mistake.

A TTB may establish that a transaction satisfies the citizenship investment amount framework.

That does not automatically mean:

• Property is fairly priced

• Rental yield is attractive

• Neighborhood is strong

• Developer is reliable

• Resale will be easy

Therefore:

Citizenship Value ≠ Investment Quality

A buyer still needs ordinary market analysis.

Example: Citizenship-Eligible but Overpriced

Suppose:

TTB

$430,000

Actual Purchase Price

$500,000

Comparable Market Evidence

420,000–420,000–440,000

The transaction might satisfy the citizenship value requirement.

But the buyer could still be paying:

60,000–60,000–80,000

above a reasonable market benchmark.

Citizenship eligibility should never be used as an excuse to ignore overpricing.

“Citizenship Eligible” Should Never Replace a Price Analysis

Foreign buyers are often presented with:

Citizenship Package — $450,000

The correct questions are:

• What is the independent market value?

• What does the TTB recognize?

• What is the DAB amount?

• What is the official sale amount?

• What amount is actually transferred?

• How does the price compare with similar units?

Only then can the investor decide whether both:

Citizenship Compliance

and:

Investment Value

make sense.

Common Foreign-Buyer Valuation Mistakes

Using an Old Valuation Rule

The mandatory foreign-buyer framework has changed.

Use current TKGM requirements.

Assuming Foreign Seller Means Mandatory Appraisal

The amended rule focuses on foreign natural-person buyers and the listed transaction categories.

Ordering a Random Private Report

Formal reports used in relevant TKGM transactions must follow the official system.

Selecting a Normal Valuation Company for Citizenship

The current citizenship route uses GEDAŞ.

Confusing Ekspertiz With TTB

They serve different functions.

Assuming Listing Price Determines Citizenship Value

It does not.

Assuming TTB Alone Is Enough

Official transaction amount, DAB and bank payment also matter.

Assuming High TTB Can Override Low DAB

If TTB exceeds the DAB for that property, the DAB amount caps the amount considered.

Adding VAT and Commission to Reach $400K

Non-property-price items should not simply be included in the qualifying declared real-estate amount.

Paying Before Planning DAB

The currency-conversion and payment structure should be designed before closing.

Combining Multiple Separate Sale-Promise Contracts

The current citizenship guide does not permit combining multiple sale-promise contracts to satisfy the threshold.

Believing an Under-Construction Property Must Be Valued at Its Future Brochure Price

The valuation rules explicitly consider completion cost and construction risk.

Citizenship Valuation Checklist Before Paying a Deposit

Property

• Property is eligible for the intended citizenship transaction

• Kat Mülkiyeti / Kat İrtifakı structure checked

• Off-plan legal structure verified

Market

• Seller asking price compared with local market

• Comparable properties reviewed

• Citizenship premium identified

Valuation

• Citizenship valuation requested through correct Web Tapu route

• GEDAŞ process understood

• Property information correct

• No assumption based only on developer's appraisal

TTB

• TTB investment determination understood

• Single-property threshold checked

• Multiple-property amounts calculated where applicable

DAB

• Correct amount planned

• Correct buyer/passport information

• Correct property identification

• DAB not lower than the investment amount required

Payment

• Bank recipient verified

• Property/DAB reference included

• Qualifying amount paid through traceable banking channel

• Payment meets threshold separately

Official Transaction

• Official sale amount meets threshold

• Non-property expenses not counted toward qualifying property amount

• Three-year restriction procedure understood

A Better Citizenship Value Workflow

Instead of:

Find $400K Listing → Pay → Ask Whether It Qualifies

use:

Confirm Citizenship Rules

→ Identify Eligible Property
→ Analyze Market Value
→ Start Official Valuation Process
→ Review TTB
→ Structure DAB
→ Structure Bank Payment
→ Complete Official Sale
→ Register Citizenship Restriction

This sequence reduces the risk of discovering a valuation problem after the purchase funds have already been transferred.

Key Takeaways

The 2026 foreign-buyer valuation system should be understood as two related but distinct frameworks.

Ordinary Foreign-Buyer Valuation

Under the amended TKGM framework, a valuation report is required where the foreign natural person is the buyer and the transaction falls within the applicable transaction categories.

Formal transaction reports are integrated into:

Web Tapu + TADEBİS

rather than being ordinary private PDFs commissioned outside the official process.

For non-citizenship transactions, the current 2024/2 framework allows the authorized valuation organization to be selected from the eligible list or through the system's automatic assignment process.

Citizenship Valuation

For citizenship-related transactions, the 2024/2 framework requires:

GEDAŞ

through the designated Web Tapu citizenship valuation route.

The current citizenship system then adds the:

TTB — Taşınmaz Edinim Sureti ile Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi

under TKGM's current 2024/4 framework.

The TTB is generated as part of the TADEBİS valuation system and contains the citizenship-specific investment amount determination.

For a single property, the TTB must support the finding that the property satisfies the applicable minimum investment amount.

For multiple properties, the qualifying USD amounts shown in their TTBs can be aggregated.

However, where a property's TTB amount exceeds its DAB amount, only the DAB amount is taken into account for that property.

The current citizenship investment threshold remains:

USD 400,000

for the applicable property-acquisition route, together with the required three-year restriction.

But reaching that threshold is not determined by listing price.

The current framework requires the relevant official sale/sale-promise amount and the documented payments to meet the statutory minimum independently, with the citizenship value verified through the TTB framework.

This creates the most important formula in Part 2:

Listing Price ≠ Valuation ≠ TTB ≠ DAB ≠ Bank Payment

For citizenship, these figures must be coordinated rather than treated as substitutes for one another.

A particularly important rule is:

If TTB > DAB → DAB Caps the Amount Considered

Citizenship buyers should also remember that transaction costs such as:

• VAT

• Commission

• Taxes

• Fees

• Other expenses

should not simply be added to the property price to manufacture the required investment threshold.

Finally, valuation rules for under-construction properties are significantly more sophisticated than simply using a developer's future sales price.

The current valuation framework requires consideration of:

• Comparable completed projects

• Completion cost

• Construction stage

• Identifiable project risks

and in high-risk incomplete projects the valuer can even decline to assign a normal value.

Therefore, the correct foreign-investor approach is:

Market Value Analysis

• Official Valuation

• TTB Where Applicable

• DAB

• Bank Payment Verification

Tapu Due Diligence
= Better Transaction Control
 

How Long Is a Property Valuation Report Valid in Turkey?

Property valuation is time-sensitive.

A valuation reflects:

• A specific property

• A specific legal and physical condition

• Market evidence

• A specific valuation date

It should therefore not be treated as permanently valid.

This is especially important for foreign buyers purchasing property for:

• Turkish citizenship

• A regulated Land Registry transaction

• Financing

• Investment analysis

because the applicable document may expire before the transaction is completed.

2026 Valuation Report Validity: 3 Months vs 6 Months

One of the most important distinctions in the current system is the date:

December 9, 2024

TKGM's current official FAQ states that:

• Valuation reports prepared before December 9, 2024 are valid for three months from their issue date

• Tutar Tespit Belgeleri — TTBs issued after December 9, 2024 — are valid for six months

Therefore:

Old-Framework Valuation Report = 3 Months

while:

Current Citizenship TTB = 6 Months

This distinction is particularly important for citizenship buyers.

Why the Date Matters

Imagine a foreign investor received a citizenship valuation report on:

November 20, 2024

That document falls under the earlier framework.

Now compare another investor whose TTB was issued on:

January 10, 2026.

The second document is governed by the newer TTB framework and has a six-month validity period.

Therefore, do not ask only:

“When was the appraisal prepared?”

Ask:

“Is this an old valuation report or a current TTB, and which validity rule applies?”

Example: TTB Validity

Suppose a citizenship TTB is issued on:

March 15, 2026

Its current six-month validity framework means the investor should structure the transaction so that the relevant citizenship-property procedure uses the document within that period.

Do not order the TTB unnecessarily early if:

• Developer completion is months away

• DAB is not ready

• Payment structure is unresolved

• Tapu transfer will be substantially delayed

Timing should be coordinated.

A Valuation Can Become Practically Outdated Before It Legally Expires

Even within the formal validity period, market circumstances can change.

For example:

• Currency movements

• Major interest-rate changes

• New metro opening

• Project completion

• Neighborhood development

• Physical damage to property

can affect the investor's economic assessment.

Therefore:

Legal document validity and investment relevance are not necessarily identical.

A report may still be legally usable while the buyer decides to perform additional fresh market analysis.

What Happens If the Property Changes After Valuation?

A valuation applies to the property characteristics evaluated at the time.

If material changes occur afterward, the previous report should not automatically be treated as a current analysis.

Examples include:

• Major renovation

• Combining apartments

• Dividing a unit

• Cins değişikliği

• Establishing a new easement

• Significant physical damage

Where registry or physical changes materially affect value, a new valuation may be necessary rather than relying indefinitely on an older report.

This is another reason to avoid ordering valuation too early in a transaction that is still changing.

What If the Valuation Is Lower Than the Purchase Price?

This is one of the most important buyer scenarios.

Suppose:

Seller Asking Price

$350,000

Negotiated Price

$330,000

Professional Valuation

$285,000

The buyer now has a:

$45,000 Gap

between the negotiated purchase price and valuation.

That does not automatically make the transaction illegal.

But it creates an investment question:

Why am I paying 330,000forsomethingindependentlyvaluedcloserto330,000forsomethingindependentlyvaluedcloserto285,000?

Possible Reasons for a Higher Purchase Price

The difference might be explained by:

• Exceptional view

• Furniture package

• Seller financing

• Unique floor

• Immediate availability

• Emotional or lifestyle value

• Limited inventory

But it may also simply mean:

The Property Is Overpriced

The buyer should investigate before closing.

Example: Paying a 15% Premium

Professional valuation:

$300,000

Purchase price:

$345,000

Premium:

$45,000

Percentage premium:

15%

The buyer should consciously decide whether the property's unique characteristics justify paying a 15% premium.

Do not let the salesperson turn this into:

“The valuation company is always conservative.”

That may or may not be true in the specific case.

Ask for evidence.

A Lower Valuation Is a Negotiation Tool

An independent report can strengthen the buyer's negotiating position.

For example:

Seller asks:

$330,000

Valuation:

$285,000

The buyer may respond commercially:

“Independent evidence suggests the property is worth materially less than the asking price.”

The seller can:

• Reduce the price

• Explain the premium

• Reject the negotiation

But the buyer now has better information.

What If the Valuation Is Higher Than the Purchase Price?

Now consider the opposite.

Professional Valuation

$350,000

Purchase Price

$300,000

This may indicate a good purchase.

Possible reasons include:

• Urgent seller

• Strong negotiation

• Distressed sale

• Family circumstances

• Property needs quick liquidity

But:

High Valuation ≠ Automatic Bargain

The buyer should still investigate:

• Tapu

• İskan

• Structural condition

• Encumbrances

• Physical/legal consistency

Sometimes a property is cheap for a reason.

Do Not Let a High Valuation Replace Due Diligence

Suppose:

Valuation: $400,000

Purchase Price: $330,000

but the apartment also has:

• Developer mortgage

• Unclear İskan

• Significant physical modifications

The valuation does not remove those problems.

The correct conclusion is not:

“The report says $400K, therefore everything is safe.”

A valuation is only one due-diligence layer.

What If the TTB Is Below $400,000?

For citizenship investors, this is much more consequential.

The current direct property-investment citizenship threshold remains:

USD 400,000

with the required three-year title restriction.

Since December 9, 2024, GEDAŞ-issued TTBs are generated after the relevant valuation comparison and evaluation process and are used according to the amount or result shown on the document.

This means:

You cannot simply tell the Tapu office that the seller says the apartment is worth more.

The TTB result matters.

Example: TTB Says $385,000

Suppose:

Listing Price

$450,000

Buyer Payment Plan

$450,000

TTB Investment Amount

$385,000

For a one-property strategy, that TTB does not establish the current:

$400,000 minimum investment amount.

The listing price does not override the TTB result.

$450K Advertisement Can Still Fail the Citizenship Value Test

This is one of the most important warnings in the entire article.

A property can be advertised as:

“$450,000 — Citizenship Guaranteed”

but still have a TTB result below the statutory threshold.

Therefore:

450KListing≠450KListing=450K Citizenship Value

Foreign buyers should never treat developer marketing as the final citizenship determination.

What Changed After December 9, 2024?

Before the current TTB system, there were circumstances where GEDAŞ valuation reports below $400,000 could be referred for further administrative review if DAB and payment evidence nevertheless satisfied the threshold.

The current framework for post-December 9, 2024 TTBs is different.

For newer TTBs, the document is generated after the system's comparison and evaluation process and is then used according to the amount or minimum-investment result shown.

This makes the modern process more direct.

Do Not Buy First and Hope to Fix the TTB Later

A dangerous sequence is:

Developer Says $450K

→

Buyer Pays

→

TTB Issued at $380K

→

Citizenship Problem

A better sequence is:

Select Property

→

Understand Current Citizenship Valuation Process

→

Obtain and Review Official Value Documentation

→

Structure DAB and Payment

→

Complete Transaction

The citizenship objective should influence the closing structure before money becomes difficult to recover.

What If the TTB Is Above $400,000 but the Purchase Price Is Lower?

Another common misconception is:

“If my TTB says 450,000,Icanbuytheapartmentfor450,000,Icanbuytheapartmentfor350,000 and still qualify.”

That should not be assumed.

The citizenship route is not based solely on the appraisal figure.

The property investment itself must meet the current USD 400,000 requirement.

Therefore:

High TTB ≠ Permission to Make a Sub-$400K Qualifying Investment

The actual transaction structure still matters.

Example

TTB

$460,000

Actual Purchase Price

$370,000

The buyer should not assume:

“The report gives me an extra $90,000.”

A valuation estimate is not cash invested.

Citizenship-by-investment requires the qualifying real-estate investment itself.

Market Value and Citizenship Value Should Be Analyzed Separately

A good citizenship investment ideally passes two tests.

Citizenship Test

Does it satisfy the official investment requirements?

Investment Test

Is it actually worth approximately what I am paying?

These are not the same question.

Example: Citizenship-Compliant but Economically Bad

Suppose:

TTB

$410,000

Purchase Price

$500,000

Comparable Market Evidence

400,000–400,000–425,000

The property may potentially satisfy the citizenship value threshold.

But the buyer might still be paying:

75,000–75,000–100,000

above reasonable market evidence.

Therefore:

Citizenship-eligible does not mean fairly priced.

The “Citizenship Premium”

Some properties are marketed specifically to foreign citizenship investors.

That can create a:

Citizenship Premium

where the foreign buyer is asked to pay more than a normal market-oriented buyer.

For example:

Local Market Price

$410,000

Citizenship Package

$470,000

Difference:

$60,000

The buyer should ask:

“What am I receiving for that additional $60,000?”

If the answer is merely:

“Citizenship service included”

the commercial value should be analyzed carefully.

How to Detect an Overpriced Citizenship Property

Use several checks.

Comparable Resales

Look at similar existing units.

Same-Project Inventory

Compare:

• Foreign-buyer price

• Domestic or resale price

• Developer price

Price Per Usable Square Meter

Not only advertised gross square meters.

Independent Market Valuation

Separate from sales office opinion.

Rental Yield

Does rent support the claimed price?

Resale Scenario

Could you sell at approximately the same price to a normal market buyer?

The last question is especially important.

Citizenship Exit Test

Before buying, ask:

“If citizenship did not exist, would another buyer reasonably pay this price for this apartment?”

If the answer is:

No

the investor may be purchasing a citizenship product rather than a strong real-estate asset.

That distinction should be intentional.

Valuation and Rental Yield

Valuation also interacts with rental economics.

Suppose:

Property Price

$400,000

Annual Gross Rent

$16,000

Gross rental yield:

4%

Now consider the same property marketed to a foreigner at:

$500,000

while rent remains:

$16,000

Gross yield falls to:

3.2%

The property itself has not changed.

Only the price paid changed.

Therefore, overpaying directly reduces investment yield.

Gross Yield Formula

A simplified calculation is:

Annual Gross Rent ÷ Property Price × 100

Example:

$18,000 annual rent

÷

$450,000 purchase price

×

100

=

4% Gross Yield

This does not include:

• Aidat

• Maintenance

• Tax

• Vacancy

• Management

• Furnishing

Net return will be lower.

Valuation and Rental Yield Are Different Analyses

A professional appraisal may use rental or income evidence where relevant.

But a foreign investor should still build their own investment model.

Ask:

• What is realistic monthly rent?

• How many months of vacancy should be assumed?

• Who pays aidat?

• Is the apartment furnished?

• What management cost applies?

• What tax applies to rental income?

A property's valuation is not its investment return.

Valuation and Emlak Rayiç / Emlak Vergisi Value

As explained in Part 1:

professional market value

and:

municipal property-tax value

serve different purposes.

A municipal value that is materially below the professional appraisal does not necessarily mean something is wrong.

The systems use different valuation methodologies and legal purposes.

Example

Professional Market Valuation

15,000,000 TRY

Emlak Vergisi Value

5,000,000 TRY

The buyer should not conclude:

“The valuer inflated the property by 10 million.”

The municipal figure is not designed simply to be an independent open-market sale valuation.

Valuation and Tapu Harcı

This distinction is also important for property-transfer fees.

For an ordinary property transfer, Tapu Harcı is calculated separately for buyer and seller at:

2% Each

on the relevant declared real transaction amount, subject to the applicable Emlak Vergisi minimum.

Therefore:

TTB / Professional Valuation ≠ Automatically the Tapu Harcı Base

The fee framework has its own statutory rules.

Example: Tapu Harcı

Actual real sale price:

12,000,000 TRY

Emlak Vergisi value:

4,000,000 TRY

Buyer cannot simply say:

“Let's declare 4 million because that is the municipal value.”

The real transaction amount remains relevant to the official transfer.

Under-Declaration Risk

If the administration later determines that the declared value did not reflect the real transaction, additional tax or fee consequences can follow.

This is why:

Low municipal value should not be treated as a tool for artificially reducing the declared purchase price.

The correct transaction should document the actual commercial amount.

Valuation and Property Taxes

A professional valuation report also does not automatically determine every future property tax.

Different taxes use different statutory bases.

Examples can include:

• Emlak Vergisi

• Valuable Housing Tax

• Rental income taxation

• Capital-gain taxation

These should be reviewed under their separate tax rules.

Therefore:

Appraisal Value ≠ Universal Tax Base

This is covered in detail in our separate Property Taxes in Turkey for Foreigners guide.

Valuation and Property Residence Permit

Property valuation and immigration should also remain separate concepts.

Türkiye's property-owner residence framework evaluates the relevant residential property and the applicant under the immigration rules.

But:

A professional valuation report does not itself grant residence permission.

The residence application is evaluated separately under immigration law.

Do Not Assume a High Valuation Makes the Residence Application Automatic

Suppose:

Property Valuation

$300,000

That does not mean:

“Residence guaranteed.”

The applicant must still meet:

• Property-owner requirements

• Residential-use requirements

• Current property-value requirements

• General residence conditions

Valuation is one property-related component, not the immigration decision.

Valuation Does Not Prove Residential Use

A unit may have a high value but legally be:

• Office

• Commercial unit

• Shop

For a property-based residence strategy, the property's residential classification and use remain important.

Therefore:

High Value ≠ Residential Eligibility

Check the property type.

Does a Valuation Report Prove the Tapu Is Clean?

No.

This is a critical distinction.

A valuation expert may review Land Registry characteristics because they can affect value.

But that does not replace independent title due diligence.

The buyer should separately confirm:

• Current owner

• Ownership share

• İpotek

• Haciz

• Şerh

• Other restrictions

Refer to the separate Tapu in Turkey for Foreigners guide.

Valuation Report vs Tapu Due Diligence

Use both.

Valuation

Asks:

“What is this asset worth?”

Tapu Due Diligence

Asks:

“What exactly do I legally own, and what rights or restrictions affect it?”

These are different questions.

Does a Valuation Report Prove İskan Exists?

No.

A valuation may review:

• Building documentation

• Legal status

• Approved project

because those factors can affect value.

But it should not replace a specific check of:

• Yapı Ruhsatı

• Yapı Kullanma İzin Belgesi

• Approved architectural project

Refer to the separate İskan in Turkey guide.

Legal Value vs Physical Value

An especially useful issue in property valuation is the distinction between:

• Actual/current use

• Legally supported use

Where the property's legal and physical situations differ, valuation documentation can identify those inconsistencies.

This is very important for renovated apartments.

Example: Enclosed Terrace

Legal project:

120 m² apartment + open terrace

Physical property:

150 m² enclosed residence

The buyer may see:

150 m²

The valuation process may need to distinguish between:

• Legally supported area

• Physical/current use

Therefore:

Extra physical square meters do not automatically equal extra legal market value.

Does a Valuation Report Prove Earthquake Safety?

No.

A real-estate valuation is not:

• Structural engineering analysis

• Earthquake performance report

• Concrete test

• Foundation assessment

The valuer may consider building:

• Age

• Condition

• Market perception

But that does not certify seismic safety.

Therefore:

Valuation ≠ Earthquake Assessment

Use the separate Earthquake-Safe Apartments in Istanbul due-diligence process.

High Value Does Not Mean Safe Building

A luxury apartment may be valued at:

$1 million

and still require structural due diligence.

Market value can be driven by:

• Location

• View

• Size

• Scarcity

rather than structural performance alone.

This distinction is particularly relevant in central Istanbul.

Can You Appeal a Property Valuation?

There are mechanisms within the TKGM/Web Tapu valuation system for correcting or reviewing valuation reports.

Correction procedures are intended for genuine issues such as:

• Factual mistakes

• Missing information

• Incorrect property data

They are not intended to manufacture a higher value.

What Can Be Corrected?

Examples can include genuine factual issues such as:

• Wrong floor

• Wrong apartment number

• Incorrect area

• Missing building information

• Incorrect property characteristic

The correction process should be used to correct facts.

“I Need a Higher Value” Is Not a Factual Error

Suppose:

Report

$380,000

Citizenship Requirement

$400,000

The buyer cannot legitimately say:

“Please change it to $405,000 because I need citizenship.”

That is not a correction request.

The valuation process must remain independent.

What Is a Control Valuation Report?

The valuation framework also recognizes:

Kontrol Değerleme Raporu

or:

Control Valuation Report

This is a separate valuation used for comparison and control when there are material concerns about:

• The value assigned

• Factors affecting value

• Significant differences between reports

It is intended to provide an additional control layer rather than allow unrestricted valuation shopping.

Why Control Reports Matter

Without a control mechanism, a buyer could theoretically:

1. Order appraisal

2. Dislike value

3. Order another

4. Repeat until one report shows the desired number

That would weaken the integrity of the valuation system.

Control procedures help reduce:

Valuation Shopping

especially where material discrepancies appear.

What If Two Valuers Disagree?

Some variation between professional valuations is normal.

For example:

Report A

$300,000

Report B

$310,000

Difference:

approximately 3.3%

That may simply reflect professional judgment.

Now consider:

Report A

$300,000

Report B

$420,000

Difference:

40%

That should create a serious question:

“Why are two professional analyses so far apart?”

The answer may involve:

• Different property data

• Error

• Different legal assumptions

• Different physical area

• Market evidence

A material discrepancy should be investigated.

Never Shop for a Citizenship Number

One of the strongest red flags is an intermediary saying:

“Don't worry, if one valuation is low we will find another company.”

The official system is specifically structured to reduce this kind of value shopping.

Citizenship buyers should seek:

Correct Value

not:

Desired ValueBuyer Decision Matrix: Purchase Price vs Valuation

Green / Yellow / Red Valuation Framework

Green

• Price supported by comparables

• Valuation close to purchase price

• Correct legal and physical information

• No citizenship value shortfall

Proceed with wider due diligence.

Yellow

• Price 5–15% above appraisal

• Unusual view or furniture premium

• Minor report corrections required

• Significant developer marketing premium

Investigate and negotiate.

Red

• TTB below required citizenship threshold

• Seller says appraisal “doesn't matter”

• Huge gap between local prices and foreign price

• Agent promises to manipulate valuation

• Multiple unexplained inconsistent reports

• Property physical area materially exceeds legal area

• Buyer is pressured to pay before official valuation

Pause the transaction.

Example: Normal Buyer

Property asking price:

$300,000

Valuation:

$290,000

Negotiated price:

$292,000

Difference from valuation:

$2,000

This is a relatively coherent price structure.

The buyer should continue with:

• Tapu

• İskan

• Technical

• Tax

due diligence.

Example: Overpriced Foreign-Buyer Package

Property asking price:

$450,000

Valuation:

$350,000

Comparable resale units:

340,000–340,000–365,000

The buyer is potentially paying:

85,000–85,000–110,000

above normal market evidence.

This should trigger serious negotiation.

Example: Citizenship Property

Purchase Price

$420,000

TTB

Shows that the minimum investment amount is satisfied.

Comparable Market Value

Approximately 410,000–410,000–425,000

This is much more coherent.

It does not guarantee future appreciation.

But citizenship and market-value objectives are better aligned.

Example: Citizenship Trap

Developer Price

$500,000

TTB

$405,000

Similar Local Resales

390,000–390,000–420,000

Citizenship requirement may potentially be met from the valuation side.

But the investor may still be paying:

approximately 80,000–80,000–110,000

above local market evidence.

The legal objective does not erase the financial loss.

Frequently Asked Questions About Property Valuation in Turkey

What Is a Property Valuation Report in Turkey?

It is a professional appraisal used to estimate the value of a real-estate asset based on its legal, physical and market characteristics.

What Is Ekspertiz?

Ekspertiz is the commonly used Turkish term for an appraisal or valuation process or report.

Formal Turkish property valuation operates through regulated professional valuation organizations.

Is Asking Price the Same as Market Value?

No.

The asking price is what the seller requests.

Market valuation is an independent estimate of value.

Is Emlak Rayiç the Same as Market Value?

No.

Municipal/property-tax values and professional market valuations serve different purposes.

Is the Tapu Transaction Amount the Same as Market Value?

Not necessarily.

The Tapu transaction amount reflects the real declared purchase/sale amount used for the official transfer.

The professional valuation is a separate estimate.

How Long Is a Property Valuation Report Valid?

Older valuation reports and current TTBs follow different validity frameworks.

Reports prepared under the earlier framework were generally subject to a shorter validity period.

How Long Is a TTB Valid?

Current TTBs issued after December 9, 2024 have a:

Six-Month Validity Period

What Is TTB?

TTB is the:

Taşınmaz Edinim Sureti ile Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi

used within the current property-based citizenship investment-value framework.

Is TTB the Same as an Ordinary Appraisal Report?

No.

It is a citizenship-specific investment-amount determination associated with the current official valuation framework.

What Happens if My TTB Is Below $400,000?

For a one-property citizenship strategy, a TTB that does not establish the current USD 400,000 minimum would not satisfy the value side of the threshold.

The seller's listing price cannot override the official result.

Can the Seller Simply Increase the Sales Contract Price?

Increasing a contract number does not independently increase professional valuation or TTB value.

What If the Valuation Is Below My Purchase Price?

You can still analyze why you are paying above the appraisal.

For an ordinary investment, this is a pricing decision.

For citizenship, the separate threshold rules must also be satisfied.

What If the Valuation Is Higher Than the Purchase Price?

That can indicate an attractive purchase, but it does not remove title, building or structural risks.

For citizenship, the actual qualifying investment still needs to satisfy the applicable USD 400,000 framework.

Can I Appeal a Low Valuation?

The valuation framework provides mechanisms for correction and review where genuine errors or relevant valuation issues exist.

A correction procedure is not a mechanism for artificially increasing a report to reach a desired citizenship number.

What Is a Control Valuation Report?

It is an additional valuation used for comparison or control where there are material concerns or discrepancies in valuation results.

Can an Estate Agent Prepare My Official Appraisal?

An agent can provide a commercial market opinion.

That is different from a regulated professional valuation used within the official valuation system.

Can a Developer Choose the Citizenship Value?

No.

The developer's sales price does not determine the official citizenship TTB result.

Does a High TTB Mean the Property Is a Good Investment?

No.

TTB addresses citizenship investment-value compliance.

It does not guarantee:

• Rental yield

• Appreciation

• Fair purchase price

• Resale liquidity

Does a Valuation Report Prove the Tapu Is Clean?

No.

Perform separate Tapu due diligence.

Does a Valuation Report Prove İskan Exists?

No.

Verify İskan and building documentation separately.

Does a Valuation Report Prove Earthquake Safety?

No.

Structural due diligence is separate.

Does a Valuation Report Guarantee Residence Permit Approval?

No.

Property residence is a separate immigration process.

Does a Valuation Report Determine Tapu Harcı?

Not by itself.

Tapu Harcı follows its own statutory transaction-value framework.

How Much Is Tapu Harcı?

For an ordinary property transfer, the standard framework is:

• Buyer: 2%

• Seller: 2%

of the relevant transaction-value base.

Can I Declare the Municipal Value Instead of the Real Purchase Price?

Not where the real transaction price is higher.

The real purchase or sale amount should be reflected within the applicable transfer framework, with the Emlak Vergisi value acting as a statutory minimum.

Final Valuation Checklist for Foreign Buyers

Property Identification

• Correct Ada

• Correct Parsel

• Correct independent section

• Correct building or block

• Correct floor

• Correct property type

Price

• Asking price identified

• Negotiated price identified

• Comparable properties checked

• Foreign-buyer premium investigated

Area

• Gross area understood

• Net usable area understood

• Legal area compared with physical area

• Terrace and balcony additions checked

Formal Valuation

• Correct official valuation route used

• Correct property purpose selected

• Report date checked

• Validity period checked

• Property information reviewed for errors

Citizenship

• Current USD 400,000 threshold confirmed

• Correct GEDAŞ/TTB route used

• TTB result understood

• Six-month TTB validity considered

• Purchase and payment structure independently satisfies current requirements

• Three-year restriction understood

Market Analysis

• Local comparable sales considered

• Same-project resale units checked

• Price per net usable m² analyzed

• View premium assessed

• Floor premium assessed

Rental Investment

• Realistic monthly rent estimated

• Gross rental yield calculated

• Aidat considered

• Vacancy considered

• Management costs considered

Tapu

• Registered owner checked

• Ownership structure checked

• İpotek checked

• Haciz checked

• Şerh checked

Building

• İskan checked

• Yapı Ruhsatı checked where relevant

• Approved project checked

• Physical and legal discrepancies investigated

Technical

• Valuation not treated as structural inspection

• Earthquake-conscious due diligence completed separately

Citizenship Buyer Final Checklist

Before paying for a property marketed as:

“Citizenship Eligible”

verify:

• Market price

• Actual negotiated price

• Official TTB

• TTB validity

• Current USD 400K threshold

• Payment structure

• DAB

• Bank payment evidence

• Official Tapu amount

• Three-year restriction

• Tapu title due diligence

• İskan and building due diligence

• Resale value after citizenship period

Most importantly:

Do not let the citizenship objective make you stop behaving like a property investor.

Final Red Flags

Pause the transaction if you hear:

“The Listing Price Is the Official Value.”

It is not necessarily.

“The Municipal Value Proves What the Apartment Is Worth.”

It does not.

“We Can Get Whatever Valuation You Need.”

Major red flag.

“TTB Is Low, but the Sales Contract Is Higher, So It Doesn't Matter.”

The TTB result matters directly in citizenship evaluation.

“This Apartment Is $500K Because It Comes With Citizenship.”

Compare the normal market.

“A High Valuation Proves the Building Is Safe.”

It does not.

“The Appraisal Checked the Tapu, So You Do Not Need a Lawyer.”

Valuation and legal title review are different.

“The Valuation Says 450K,SoYouCanPayOnly450K,SoYouCanPayOnly350K.”

Do not assume this satisfies the current citizenship investment requirement.

“Declare the Municipal Value to Reduce Tapu Fees.”

The real transaction amount remains relevant to the official transfer.

The Foreign Buyer's Ultimate Valuation Framework

Before purchasing, answer eight questions.

1. What Is the Asking Price?

What does the seller want?

2. What Is the Negotiated Price?

What will you actually pay?

3. What Is the Professional Market Value?

What does independent valuation support?

4. What Is the Municipal Value?

Understand it as a separate tax-related value.

5. What Is the Tapu Transaction Amount?

It should reflect the real transaction in accordance with the current fee framework.

6. If Citizenship Is Involved, What Does the TTB Say?

Do not rely on marketing.

7. Is the Property a Good Investment at the Price You Are Paying?

Analyze yield and resale.

8. Have You Completed Separate Legal and Technical Due Diligence?

Valuation cannot answer everything.

The Complete Valuation Formula

A weak buyer thinks:

Seller Says 400K→PropertyIsWorth400K→PropertyIsWorth400K

A stronger buyer separates:

Asking Price

≠ Negotiated Price
≠ Professional Market Value
≠ Emlak Vergisi Value
≠ Tapu Transaction Amount
≠ DAB
≠ TTB

Each number exists for a different reason.

The Complete Property-Investment Formula

Use:

Market Valuation

• Comparable Sales

• Tapu Due Diligence

• İskan Due Diligence

• Structural Review

• Rental Analysis

• Tax Analysis
  = Better Property Decision

For citizenship:

Better Property Decision

• Current Citizenship Compliance

• TTB

• Correct Payment Structure

• Three-Year Restriction
  = Better Citizenship Investment

Conclusion

Property valuation in Türkiye is much more than asking:

“How much is this apartment worth?”

A foreign buyer may encounter multiple values during a single transaction:

• Seller asking price

• Negotiated price

• Professional appraisal

• Municipal or property-tax value

• Tapu transaction amount

• DAB

• Citizenship TTB

These numbers should never be treated as synonyms.

A seller's asking price reflects:

what the seller wants.

A professional valuation estimates:

what the property may reasonably be worth under the applicable valuation framework.

The Emlak Vergisi value belongs to a different statutory tax system.

The Tapu transaction amount reflects the actual declared sale transaction within the Land Registry and fee framework.

And the TTB exists specifically within the modern citizenship investment-value system.

The timing rules are also important.

Current TTBs issued after December 9, 2024 have a:

Six-Month Validity Period

Citizenship investors should pay particular attention to the TTB result.

For current TTBs, the document is produced after the official valuation comparison and evaluation process and is then used according to the minimum-investment finding or amount stated on it.

Therefore:

A $450,000 advertisement cannot override a TTB that does not support the required investment value.

The current citizenship-by-property threshold remains:

USD 400,000

with the required restriction against resale for at least:

Three Years

under the applicable investment framework.

But citizenship eligibility is only one side of the purchase.

An apartment can meet the citizenship investment test and still be:

• Overpriced

• Low-yielding

• Difficult to resell

• Poorly located

The foreign investor should therefore analyze both:

Legal Qualification

and:

Economic Value

A valuation report also cannot replace title due diligence.

It does not automatically prove:

• Clean Tapu

• No mortgage

• No attachment

• Normal İskan

• Structural safety

Those questions belong to other due-diligence processes.

Property-based residence is also separate from valuation.

Likewise, Tapu Harcı has its own statutory valuation basis and should not automatically be derived from a professional appraisal or TTB.

The central rule of this guide is therefore:

Always ask what a number represents before relying on it.

If someone tells you:

“The official value is $450,000.”

ask:

“Which official value?”

Is it:

• The asking price?

• An independent appraisal?

• The Tapu amount?

• DAB?

• TTB?

• Municipal tax value?

Until that question is answered, the number has very little meaning.

The strongest foreign buyer combines:

Correct Valuation + Correct Legal Structure + Correct Building Documentation + Correct Investment Analysis

rather than purchasing based on one headline price.