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Turkish Blue Card

Turkish Blue Card (Mavi Kart): Inheritance and Property Rights in Turkey Explained | Doğru Kanzlei

Av. Hasan Doğru
May 1, 2025
18 min read
Turkish Blue Card (Mavi Kart): Inheritance and Property Rights in Turkey Explained | Doğru Kanzlei
*This article is for general information only and does not constitute legal advice. Please consult a qualified lawyer for guidance on your specific situation.*

If you gave up Turkish citizenship to obtain a German passport, you may have assumed you were starting from scratch in Turkey — that you were now a foreigner, with all the limitations that implies for property ownership and inheritance.

The reality is considerably better than that. But only if you know about it.

Turkish law specifically addresses your situation through a document called the Mavi Kart — the Turkish Blue Card. Under Article 28 of Turkey's Citizenship Law (Türk Vatandaşlığı Kanunu — TVK, Law No. 5901), former Turkish citizens who gave up their citizenship with government permission retain a substantial set of rights in Turkey — including the right to buy and sell real estate without the restrictions that apply to other foreign nationals, and the full inheritance rights of a Turkish citizen.

Hundreds of thousands of people living in Germany, the Netherlands, Austria, and other European countries hold or are eligible for a Mavi Kart. Many do not fully understand what it gives them — or have not yet applied for one.

This guide explains what the Mavi Kart is, what rights it preserves, how it works in practice for property purchases and inheritance, how Turkish estates interact with German succession law, and the tax implications for Mavi Kart holders in Germany.

What Is the Mavi Kart?

The Mavi Kart (Blue Card) is a status document issued by the Turkish state confirming that its holder was formerly a Turkish citizen, renounced Turkish citizenship with state permission, and retains specified rights in Turkey under Art. 28 TVK.

It was previously known as the Pembe Kart (Pink Card) or İzin Belgesi (permit document). The current Mavi Kart format was introduced when Turkey reformed its citizenship law in 2009 with Law No. 5901.

Important: The Mavi Kart is not a passport or an identity document. It is a status certificate. It does not allow re-entry to Turkey as a Turkish national — you use your German (or other) passport for travel. But it unlocks a specific set of rights that distinguish you from an ordinary foreigner.

Who Is Eligible?

Anyone who:

  • Was formerly a Turkish citizen
  • Renounced Turkish citizenship with government permission (izinle) — typically to naturalise in another country
  • Has not had their former Turkish citizenship revoked as a penalty or lost it involuntarily
  • The key distinction is voluntary, permitted renunciation. People who lost Turkish citizenship without permission — for example, by acquiring another nationality without applying for renunciation — are in a different category and should take legal advice on their specific situation.

    The Rights Preserved Under Art. 28 TVK

    Article 28 of the Turkish Citizenship Law sets out an exhaustive list of rights that Mavi Kart holders retain:

    RightWhat It Means
    Real property acquisitionBuy, sell, gift, and inherit Turkish real estate without the restrictions that apply to regular foreign nationals
    InheritanceFull statutory heir status and testamentary capacity under Turkish Civil Code
    Business activitiesEstablish and operate companies and commercial enterprises in Turkey
    Social security accessJoin certain Turkish social security schemes (SGK)
    Access to public servicesUse certain state facilities and services

    What the Mavi Kart Does NOT Give You

    RightPosition
    Voting rightsNo — cannot participate in Turkish elections or referendums
    Public officeNo — cannot serve as civil servant, judge, or elected official
    Turkish passportNo — travel with your foreign nationality passport
    Military serviceArt. 29 TVK: Mavi Kart holders are exempt from military service obligations
    Consular protection by TurkeyNo — Turkey does not provide consular protection to Mavi Kart holders as it would to its own nationals

    Buying Property in Turkey as a Mavi Kart Holder

    Why Mavi Kart Holders Have an Advantage

    Turkey imposes significant restrictions on property purchases by regular foreign nationals. Under Turkish land registry law and the rules governing foreign persons' real estate acquisition:

  • Reciprocity requirement: Only nationals of countries that allow Turkish citizens to buy property can purchase Turkish real estate
  • Area limits: A foreign national may not own more than 10% of the total surface area in any single district (ilçe), and no more than 30 hectares in total across Turkey
  • Restricted zones: Military zones and certain strategically sensitive areas are entirely closed to foreign purchasers
  • Mavi Kart holders are exempt from all of these restrictions. They transact exactly as Turkish citizens do.

    The Purchase Process at the Land Registry (Tapu Müdürlüğü)

    The Turkish land title transfer happens at the land registry office — unlike in Germany or the UK where the notary is central. The process:

    1.Agree on sale price and prepare contract — can be managed from Germany via power of attorney
    2.Obtain a Turkish tax ID number (vergi kimlik numarası) — available at any Turkish tax office; German passport suffices
    3.Book a Tapu Müdürlüğü appointment — both parties (or their authorised representatives via power of attorney) attend
    4.Documents required: Mavi Kart + German passport + Turkish tax ID + passport photos + (sometimes) a municipal valuation document
    5.Pay title transfer fee (Tapu Harcı) — currently 4% of the declared sale price, split equally between buyer and seller
    6.Collect the title deed (tapu senedi)
    ⚠️ Practical note: Not all land registry clerks are familiar with the Mavi Kart status. It does happen that a Mavi Kart holder is initially treated as a regular foreign national, triggering requirements for additional permits. Your lawyer can resolve this quickly with a written reference to Art. 28 TVK — and if necessary, by escalating to the regional land registry directorate (TKGM).

    Inheritance Rights for Mavi Kart Holders

    Inheriting From a Turkish Estate

    Mavi Kart holders stand in the same position as Turkish citizens in the Turkish succession framework. Specifically:

  • They are statutory heirs in the first line (children, grandchildren), second line (parents, siblings), or third line (grandparents) under the Turkish Civil Code (TMK)
  • They can be named as beneficiaries in a Turkish will
  • Their forced share (saklı pay) is protected — they can bring a tenkis (forced-heirship reduction) claim if the deceased exceeded the disposable portion, or a muris muvazaası (sham-transfer cancellation) claim if the deceased used a fake sale to cut them out
  • They can file these claims before Turkish courts and enforce judgments
  • All of these rights apply in exactly the same way as they would for a Turkish citizen. The Mavi Kart status does not diminish them.

    When a Mavi Kart Holder Dies: Which Law Governs?

    If a Mavi Kart holder is habitually resident in Germany and dies leaving assets in both countries — including real property in Turkey — two legal systems must be navigated simultaneously.

    EU Succession Regulation No. 650/2012 (Brussels IV):

    The Regulation applies to the estates of persons who die habitually resident in an EU member state. It generally points to the law of the habitual residence — German law for a Germany-resident Mavi Kart holder — as governing the estate.

    The Lex Situs Exception:

    Art. 1(2)(l) Brussels IV expressly excludes from the Regulation's scope "the nature of rights in rem" over immovable property. In practice, Turkish courts and the Turkish land registry process Turkish real estate under Turkish law regardless of what Brussels IV says about the overall estate. Turkey is not an EU member and does not apply Brussels IV.

    The practical result is a two-track estate:

    Asset TypeApplicable LawForum
    German bank accounts, car, securitiesGerman succession lawGerman probate court
    Turkish real propertyTurkish succession law (TMK)Turkish probate court / land registry

    This split means the estate often needs legal management in both countries simultaneously — with the two-track approach coordinated by a lawyer familiar with both systems.

    Mixed-Nationality Estates: Mavi Kart Parent, German Children

    A very common scenario: one or both parents hold a Mavi Kart. Their children were born in Germany and have only German citizenship — they were never Turkish nationals.

    What Can the Children Inherit?

    Children who were never Turkish citizens inherit as regular foreign nationals (yabancı) under Turkish law. The following applies:

  • For most types of real property (residential, commercial, agricultural in non-restricted areas): inheritance and land registry transfer is possible
  • Military exclusion zones and strategic security areas cannot be transferred to foreign nationals — these properties must be liquidated and proceeds distributed
  • The documentation and processing requirements are more demanding than for Turkish citizen heirs
  • Timeline: registration processes for foreign-national heirs can take longer
  • Planning Ahead

    If you are a Mavi Kart holder with Turkish real property and children who do not have Turkish citizenship, consider:

    Option 1 — Lifetime transfer (inter vivos gift): Transfer the property to your children now, while you are alive, under the favorable Mavi Kart transaction terms. After your death, they would hold the property as already registered owners, not as foreign-national heirs navigating the Turkish probate system.

    Option 2 — Turkish will: Draft a separate will in Turkish, governed by Turkish law, specifically addressing your Turkish real property. This minimises ambiguity and potential disputes between heirs.

    Option 3 — Accept the two-track process: If no action is taken, the estate will proceed as described above — straightforward for Mavi Kart holders who also inherit, more complex for German-only heirs. Legal representation in Turkey handles the process, but timeline and cost should be factored in.

    Tax Implications for Mavi Kart Holders in Germany

    Rental Income from Turkish Property

    As a tax resident of Germany, you are subject to German income tax on your worldwide income — this includes rental income from Turkish properties.

    The German-Turkish Double Taxation Agreement (DTA, 2011) governs the allocation:

  • Turkey has the primary right to tax income from Turkish immovable property
  • Germany applies the credit method: Turkish income tax paid is credited against the German income tax liability
  • Result: you pay Turkish income tax on rental income and declare it in Germany, but receive a credit for the Turkish tax paid — avoiding full double taxation
  • Capital Gains on Property Sales

    Selling a Turkish property may trigger tax in both countries:

    In Turkey (Değer Artışı Kazancı — capital gains):

  • Property held for more than 5 years: no Turkish capital gains tax
  • Property held for less than 5 years: subject to Turkish income tax on the gain
  • In Germany (§ 23 EStG — speculative gain):

  • Property held for more than 10 years: German speculative gain tax does not apply
  • Property held for less than 10 years: the gain is subject to German income tax; Turkish tax paid is credited under the DTA
  • The 5-year Turkish and 10-year German thresholds do not align, creating a window (years 5–10) where Turkey does not tax the gain but Germany may. Tax advice from someone who knows both systems is essential.

    Inheritance Tax

    Germany levies inheritance tax (Erbschaftsteuer) on worldwide assets when either the deceased or the heir is resident in Germany (§ 2 ErbStG). Turkish property inherited by a German resident therefore falls within the German inheritance tax base.

    Turkey also levies a Veraset ve İntikal Vergisi (inheritance and gift tax), but at very low rates compared to Germany (0.5% to 10% depending on value and relationship degree).

    There is no bilateral estate tax treaty between Germany and Turkey — which means the inheritance of Turkish property by a German resident can result in tax exposure in both countries, requiring careful planning and potentially German-Turkish tax specialist advice.

    Applying for or Replacing a Mavi Kart

    First-Time Application

    If you renounced Turkish citizenship to obtain German nationality but never applied for a Mavi Kart, you can do so at any time:

    In Germany: At the Turkish General Consulate in Berlin, Hamburg, Frankfurt, Cologne, Munich, Stuttgart, or Hanover.

    In Turkey: At a provincial office of the Immigration Administration (Göç İdaresi Müdürlüğü).

    Typical documents required:

  • Proof of renunciation of Turkish citizenship (İzin Belgesi — the permission document)
  • Valid foreign passport (German passport)
  • Passport photographs
  • Lost or Expired Mavi Kart

    A lost or damaged card can be replaced at the consulate. The underlying rights under Art. 28 TVK do not lapse — the card is only the proof, not the right itself. However, without the card, enforcing those rights before Turkish bureaucratic authorities is significantly more difficult in practice.

    Doğru Kanzlei: Advising Mavi Kart Holders in Europe

    Doğru Kanzlei holds dual bar membership — Ankara Bar (Reg. No. 47068) and Karlsruhe Bar (§ 207 BRAO). We advise Mavi Kart holders throughout Germany, Austria, Switzerland, the Netherlands, and the UK on Turkish property acquisition, inheritance planning, and estate disputes.

    Typical mandates include:

  • Mavi Kart holders facing bureaucratic resistance at Turkish land registry offices — we intervene with a written Art. 28 TVK reference and, if necessary, escalate administratively
  • Estate planning for Mavi Kart holders who own Turkish real property and have German-only children — evaluating lifetime transfer versus testamentary transfer
  • Inheritance proceedings after the death of a Mavi Kart holder — coordinating the two-track German/Turkish estate process
  • Forced-heirship and sham-transfer claims in Turkey on behalf of Mavi Kart holder clients
  • In an initial consultation, we assess your Mavi Kart status, your specific property or inheritance question, and the next practical steps.

    Book a consultation with Doğru Kanzlei →

    This article is also available in German:

    Blaue Karte (Mavi Kart): Erbrecht und Immobilien in der Türkei →

    This article is also available in Turkish:

    Mavi Kart ile Türkiye'de Miras ve Gayrimenkul Hakları →

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