Title Transfer Fees Decision Framework in Türkiye
The purpose of a decision framework is not to repeat a list of risks. It is to determine what to do with the evidence in front of you. A reviewer should be able to move from the fee documents to one explicit outcome: proceed, proceed with a condition, recalculate, escalate for specialist review, or stop. Every outcome should be tied to reviewable evidence rather than a verbal assurance.
Decision input 1: Is the transaction type defined?
If it is not clear that the transfer is an ordinary sale, do not automatically apply sale-fee rules. Classify the transaction first. Gifts, partitions, exchanges and other transfers can have different charge consequences. A correct fee decision starts with a correct legal description of the transaction.
Decision input 2: Is the value base valid?
Compare the agreed commercial price, the value intended for declaration and the current municipal property-tax value. TKGM’s sale guidance states that the fee is based on the declared sale value, which may not be lower than the property-tax value. If the proposed declaration falls below that floor or cannot be reconciled with the real transaction, the decision is hold and verify, not merely “proceed with caution.”
Decision input 3: Are buyer and seller amounts calculated correctly?
Once the base is valid, apply the current official sale rule: 20 per thousand separately for the buyer and 20 per thousand separately for the seller. If a cost sheet shows one combined percentage without identifying the parties, choose recalculate. A private agreement shifting the economic burden can be recorded separately but should not distort the official verification logic.
Decision input 4: Does the revolving-fund amount use the current tariff?
Check the tariff year and service type. TKGM announced that the 2026 revolving-fund tariff took effect on 1 January 2026. If the amount was copied from an old closing or another tariff year, choose recalculate before payment. A figure being “close enough” is not adequate control.
Decision input 5: Is every cost classified?
Separate title-deed tax, revolving-fund service charges and private professional costs. If a private charge is labelled as a government fee, choose clarify and correct the documentation. If the party requesting money refuses to itemise or provide a basis, escalate the decision to stop.
Decision input 6: Is there an official collection reference?
Before a government charge is paid, it should be traceable to the official collection reference for the current transaction. TKGM’s e‑Tahsilat guidance describes the 12- or 13-digit collection number. If the reference matches the current file, the process can move to payment. If it belongs to another transaction or cannot be verified, the decision is stop and correct.
Decision input 7: Is the payment channel appropriate?
An official or supported banking route that produces a complete receipt supports a proceed decision. A request to send a government charge to a personal account or unknown link is an immediate stop. Private services should be paid under their own genuine agreement and should not be disguised as land-registry charges.
Decision input 8: Has anything material changed before closing?
On closing morning, or when a new notice arrives, compare the amount, collection reference and value against the version on which the earlier decision was based. A material change reopens the decision. An old “approved” worksheet should not remain valid automatically after the inputs change.
Five practical decision outcomes
- Proceed: transaction type, value, statutory fee, tariff, collection reference, payment channel and evidence all reconcile.
- Proceed with condition: a limited gap exists, with a named owner, deadline and closing evidence, and it does not justify payment before resolution if it affects amount or legitimacy.
- Recalculate: the legal rule is clear but the value, tariff or arithmetic is wrong.
- Escalate: the file involves an exemption, unusual transfer, legal interpretation or tax issue outside routine operational review.
- Stop: wrong reference, unofficial payment route, indefensible value, material contradiction or pressure to pay without verification.
What closes a condition?
A condition is not closed by writing “resolved.” Identify the evidence that removes it: an updated property-tax value, corrected calculation, new valid collection reference, current tariff, official receipt or specialist opinion for a special case. Preserve the evidence that changed the decision, the date and the reviewer.
How should the decision be recorded?
Write a concise control note answering: what is the transaction, what value is used, what official charges apply, which tariff applies, what collection reference controls, what discrepancies remain, what is the outcome and what condition is open? A new reviewer should be able to reproduce the conclusion without relying on memory.
Frequently asked questions
What is the effect of the municipal property-tax value floor?
It limits the value base that can be used for the sale-fee calculation. A proposed declared value below that floor should not be approved for calculation until corrected.
Who confirms the current property-tax value?
Use the competent municipal or official route for the current value and then connect it to the land-registry transaction. Do not rely on an old advertisement or an unsupported number.
What proves a fee problem is actually resolved?
New evidence that addresses the original cause and allows the fee to be recalculated or reconciled—rather than another verbal assurance.
Can a transaction proceed with an open item?
Only where the gap is limited, the condition is documented, the owner and evidence are defined, and no payment or registration dependent on that issue occurs before the required evidence is obtained.
This framework is an operational decision tool and does not replace specialist legal or tax interpretation for exemptions or unusual transfers.