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Before You Invest in a Turkish Fund: Bylaws, Issuance Document and Agreements

There are three documents to read before investing in a Turkish real estate or venture capital fund. This guide explains what each one is, what it contains and where to find it.

Short answer: The bylaws (içtüzük) are the fund's constitution: founder, purpose, investment limits, entry and exit rules and liquidation. The issuance document (ihraç belgesi) sets out how units are sold: price, place of sale, fees, risks and tax. The subscription agreement is signed between the investor and the founder or the distributor (bank or brokerage) and governs the purchase of units. The bylaws and issuance document are approved by the Capital Markets Board (CMB) and published on KAP.

1. What are the fund bylaws (içtüzük)?

The bylaws are the founding document and core rulebook of a Turkish investment fund: in effect, its constitution.

What they contain

Fund name and type, founder and portfolio manager, custodian, investment objective and strategy, investment limits, rules for buying and redeeming units, fund expenses and fees, valuation principles, term and liquidation rules.

Who drafts and approves them

The founding portfolio management company drafts them and the CMB approves them. Any change also requires CMB approval, a key safeguard for investors.

2. What is the issuance document (ihraç belgesi)?

The issuance document explains how units are sold and what the investor is buying. For REIFs and venture capital funds sold to qualified investors, it is the main document to read before signing.

What it contains

Investment strategy and target assets, how the unit price is calculated, subscription and redemption windows, minimum investment, management fee and other costs, risks, taxation and ongoing disclosures.

Why it matters

It tells you when and how you can get your money back, which fees you pay and which risks apply. For a citizenship investment, the three-year holding and exit rules are set out here.

3. What is the subscription agreement?

This is the agreement the investor signs when entering the fund, with the founder or the distributor that sells the units (a bank or brokerage). It covers the purchase order, payment, crediting of units to the investor's account, redemption terms and each party's responsibilities, and it refers to the bylaws and issuance document.

Other things to know

Custody

Fund assets are held by the custodian and units sit in the investor's own account. The manager cannot use fund assets for its own account.

Valuation

Properties are valued by CMB-licensed appraisal firms, and the unit price is calculated from these values.

KAP disclosures

Bylaws, issuance document, financial reports and material events are published on KAP, open to anyone.

Independent audit

The fund's financial statements are independently audited and the results shared with investors.

Documents in a citizenship investment

  1. Bylaws and issuance document: reviewed before investing; they show the fund qualifies and the three-year holding rule.
  2. Subscription agreement: signed when opening the account at the bank or brokerage.
  3. Currency conversion receipt and unit purchase confirmation: proof of the USD 500,000 investment.
  4. CMB conformity letter: issued by the CMB after the units are bought and sent to your lawyer; the citizenship application starts with it.

See Turkish citizenship through fund investment for the full process. FT Portföy fund documents are published on KAP, and English translations are available on request. Türkçe

Frequently asked questions

What is the difference between the bylaws and the issuance document?

The bylaws set the fund's permanent core rules; the issuance document explains the terms of the unit offering, fees, risks and taxation to investors.

Where can I find a fund's documents?

The bylaws and issuance document are published on the fund's page on KAP (kap.org.tr) and can also be requested from the founding portfolio management company.

Are the documents available in English?

The official documents are in Turkish. FT Portföy provides English translations for information to foreign investors.

Can the bylaws be changed?

Yes, but only with CMB approval, and material changes are announced to investors.

Which agreement will I sign?

You sign an account and subscription agreement with the bank or brokerage through which you buy units; it refers to the fund's bylaws and issuance document.

Author
Serkan Topaktaş, Chairman of FT Gayrimenkul ve Girişim Sermayesi Portföy Yönetimi A.Ş., a portfolio management company licensed by the Capital Markets Board of Türkiye. He works on structuring real estate and venture capital funds and their tax planning.
Last updated: 12 October 2026

Related guides: Real estate investment funds in Turkey · Venture capital fund tax benefits · Turkish citizenship through a fund · FT Portföy

This page is general information, not an investment offer or investment, tax or legal advice. Tax law can change; please confirm your own position with a tax adviser. Fund units carry risk and their value may go up or down; past performance is not a guarantee of future results.

Sources: Capital Markets Board of Türkiye · Public Disclosure Platform (KAP).

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