Source Freshness Review — Property Valuation Report
A freshness review of a Turkish property valuation should not begin with the single question, Is there a report? It should establish what regulatory purpose the valuation serves, when the document was produced, and whether that document type is still the one required by the competent authority. This matters because the treatment of transactions involving foreigners changed on 9 December 2024. TKGM Circular 2024/4 states that a valuation is no longer required merely because a foreigner is a party to an ordinary transaction, while real-estate transactions used for citizenship continue to use the investment amount confirmation document known as TTB, derived from the designated valuation process.
Identify the document before measuring its age
Do not treat property valuation report as a permanent, uniform document label. GEDAŞ valuation reports issued before 9 December 2024 were subject to a different validity rule from TTB documents issued under the later regime. TKGM states that pre-change valuation reports were valid for three months from issue and, when an application was made within that period, remained usable until that application was completed. A TTB issued after 9 December 2024 is valid for six months. The file should therefore record the document type, issue date and transaction application date, not merely the date on which a PDF copy was downloaded.
Match the report to the exact asset and purpose
A recent document is still unusable if it concerns the wrong unit or a different transaction purpose. Reconcile province, district, neighbourhood, block, parcel and independent-unit identifiers with current title data, and compare registered use, relevant area data and ownership references. For citizenship, confirm that the valuation was requested through the citizenship-specific route and that the resulting TTB entered the prescribed electronic system. Circular 2024/4 explains that a physically presented TTB is not processed in place of the system-delivered document. A change in units, parcel structure or transaction composition requires a fresh assessment of whether earlier evidence still covers the actual investment.
Check the professional source
A company logo on a report is not enough. Retain the valuation company name, report number and valuer identification where available, then check the current professional source appropriate to the procedure. The Capital Markets Board, SPK, publishes information on real-estate valuation organisations, while TKGM uses the GEDAŞ, TADEBİS and WebTapu process for valuations relevant to foreigner and citizenship procedures. Evidence that a company was acceptable years ago does not by itself establish that it is the correct source for a new regulated transaction.
Separate market value from document validity
A plausible value does not prove that a report is current, and an in-date report does not guarantee that nothing material has changed. Subdivision or merger, a change of registered use, major construction progress, physical damage, substantial renovation or a change in legal constraints may undermine reliance even before the nominal validity period expires. Record those events as change triggers. Also do not treat the amount stated in a TTB as automatically binding for land-registry fee purposes; Circular 2024/4 expressly separates the TTB amount from binding determination of the title fee base.
Apply the citizenship value test correctly
For citizenship transactions, reconcile the values required by the current framework rather than selecting the most favourable number. The amount declared in the official deed or preliminary sale promise, the total price transfers or payments and the amount confirmed under the valuation and TTB process must each satisfy the applicable investment test. A compliant valuation does not prove that funds moved, so DAB and bank payment records remain separate evidence. TKGM also states that the interval between the TTB and the citizenship-related transaction application may not exceed six months; when it does, the underlying valuation basis must be renewed.
Create a reproducible freshness record
The review note should show the date TKGM and SPK sources were last checked, document type, issue date, purpose, exact property, issuing or processing organisation and the reason the document is still relied upon. Preserve superseded valuations as history rather than deleting them, but label them clearly so they cannot be mistaken for the controlling evidence. This distinction allows an older report to remain useful for trend comparison while preventing it from silently governing a transaction after the regulatory or factual basis has changed.
FAQ
Does every foreign purchase require a valuation report in 2026?
No. TKGM says that after 9 December 2024 a valuation is not required solely because a foreigner is involved in an ordinary transaction. Citizenship transactions use the specific TTB framework.
How long is a post-change TTB valid?
TKGM states six months, subject to renewal of the valuation basis when the interval to the citizenship application exceeds that period.
Can a paper TTB substitute for the system record?
No. Circular 2024/4 specifies the designated system transmission and states that physically submitted TTB documents are not processed as a substitute.
Official sources
- TKGM — Circular 2024/4: https://www.tkgm.gov.tr/yabancii-db/turk-vatandasligi-kanunu-uygulama-yonetmeligi-hk-20244-sayili-genelge
- TKGM — Valuation validity: https://www.tkgm.gov.tr/yabancii-db/degerleme-raporunun-gecerlilik-suresi-var-midir
- TKGM — Foreigners FAQ: https://www.tkgm.gov.tr/en/yabancii-db-sikca-sorulan-sorular
- SPK — Real-estate valuation organisations: https://spk.gov.tr/kurumlar/gayrimenkul-degerleme-kuruluslari