Türkiye’s penalty for underpaid title deed fees has quadrupled. Explore 2026 transfer fees, the 100% penalty and buyer and seller obligations.
What Could Underdeclaring the Price of a TRY 10 Million Home Cost?
Buyers and sellers who declare a property sale price below the amount actually paid now face higher financial penalties in Türkiye. The tax loss penalty on underpaid title deed transfer fees has risen from 25% to 100% of the unpaid fee.
Article 6 of Law No. 7566, published in Official Gazette No. 33112 on 19 December 2025, amended the penalty in Article 63 of Fees Law No. 492. Under Article 38 of the amending law, the change took effect on 19 December 2025. The effective date is not 1 January 2026. The penalty applicable to an earlier transaction must be assessed separately, with reference to its date and the relevant legislation. Law No. 7566, Articles 6 and 38
The change makes accurate declarations and cost planning particularly relevant to buyers and sellers of homes, land, commercial premises and investment properties.
Why Has the Title Deed Tax Penalty Quadrupled?
In a property sale, the title deed transfer fee is calculated on the actual sale price, which must not be below the property tax value. Declaring a lower sale price to reduce the fee creates a risk of additional assessment and penalties.
Previous penalty rate: 25% of the underpaid title deed transfer fee.
New penalty rate: One times the underpaid fee, equivalent to 100%.
The fourfold increase concerns the penalty rate on the unpaid fee. General sale transactions are calculated using a 2% transfer fee for the buyer and a separate 2% fee for the seller. The underpaid fee itself and any applicable interest are collected in addition to the penalty. Fees Law No. 492, Article 63 and Tariff No. 4
Penalty for Underdeclaring a Sale Price: A Worked Example
Suppose a home with an actual sale price of TRY 10,000,000 is declared at TRY 6,000,000 in the title deed transaction. The undeclared difference is TRY 4,000,000.
Actual sale price: TRY 10,000,000.
Declared sale price: TRY 6,000,000.
Undeclared difference: TRY 4,000,000.
Total underpaid transfer fee (4%): TRY 160,000.
Tax loss penalty at the previous rate (25%): TRY 40,000.
Tax loss penalty at the new rate (100%): TRY 160,000.
In this hypothetical example, the combined additional liability of buyer and seller comprises TRY 160,000 in unpaid fees and TRY 160,000 in tax loss penalties. The combined additional cost could reach TRY 320,000 before interest.
For each party separately, the calculation gives TRY 80,000 in underpaid fees plus TRY 80,000 in penalties. The buyer’s additional liability would therefore be TRY 160,000 before interest, with the same amount for the seller. These figures are additional to the fees already paid on the declared price.
The example assumes the general transfer fee rates and the full 100% penalty, with no exemption or penalty reduction. The transaction’s circumstances, date and applicable legal provisions can affect the actual assessment.
Who Pays the Title Deed Transfer Fee: Buyer or Seller?
For general property sales in Türkiye, transfer fees are collected separately from the buyer and seller. The general rates for 2026 are 2% of the fee assessment base for the buyer and 2% for the seller, totalling 4%. Transactions covered by an exemption or a special rule require a separate assessment. General Directorate of Land Registry and Cadastre transaction guide
The parties can agree between themselves on a different allocation of the expenses. That agreement does not automatically remove their statutory fee obligations. An understated sale price therefore concerns both parties.
Is Declaring the Municipal Property Tax Value Enough?
A common misconception is that declaring only the property tax value set by the municipality is sufficient. The transfer fee base is the actual sale price, subject to a minimum of the property tax value.
For example, if a home has a municipal property tax value of TRY 3 million but actually sells for TRY 8 million, declaring only TRY 3 million creates a risk of underpaid fees and penalties. The municipal value does not replace the actual sale price.
What Should Property Investors Check?
For high value home and land purchases, transfer fees should be included in the acquisition budget from the outset. Buyers and sellers should consider the following:
1. Declare the actual sale price. Use the price genuinely agreed by the parties and check the minimum property tax value.
2. Keep payment records. Bank transfer receipts, sale agreements and payment documents can support the accuracy of the transaction.
3. Calculate transaction costs in advance. Include transfer fees, the land registry service charge and other expenses in your budget.
4. Review previous transactions with a specialist. If a sale price may have been understated, consult an accountant or tax law specialist, taking the transaction date into account.
5. Plan the sale using accurate information. Property advice can help with selecting a property and planning the transaction; individual tax assessments should be handled by the relevant specialist.
What Does This Mean for the Antalya Property Market?
When comparing properties in Altıntaş, Lara, Konyaaltı and other Antalya investment locations, consider the total acquisition cost alongside the purchase price. Calculating transfer fees and transaction expenses in advance makes the budget more transparent.
Accurate pricing, documented payments and a truthful sale price declaration are key elements of a secure process for both buyer and seller. Seeking a short term saving by understating the sale price may lead to a greater financial liability.
To explore homes, land or investment properties in Antalya, view my current projects or contact me to plan the process together.
Category: Property News / Legislation.
Legal information: This article is based on the general legislation in force as of October 2026. Tax obligations may vary with the date and specific circumstances of the transaction. The content does not replace legal or tax advice.