Türkiye’s investor route has a statutory root, Argentina’s a decree

Türkiye and Argentina both provide for citizenship by investment, on different footing. Türkiye ties its route to a statute Parliament voted, with thresholds set by regulation, and its Interior Ministry reports 6,134 people’s citizenship annulled or withdrawn. Argentina’s route, announced but not opened, relies on an emergency decree with no floor vote on record, and its amounts appear in no Argentine Official Gazette act found.

What each route rests on

Türkiye’s investor citizenship route, in force and applying, starts in Law 5901, article 12(1), under which the President grants citizenship by decision to listed groups of foreigners. Sub-clause (b), added by Parliament in 2016, covers certain residence-permit and Turquoise Card holders and their families. The Interior Ministry says the investor route runs under it and article 20 of the implementing regulation.

Article 12 names no investment and no amount. Article 20(2) of the regulation lets a foreigner who meets any listed condition acquire citizenship under sub-clause (b) by Presidential decision: at least USD 400,000 of property bought with a three-year bar on sale, at least USD 500,000 in other listed investments, or at least 50 jobs created.

Argentina’s investor citizenship route rests on Decree 366/2025, an emergency decree (decreto de necesidad y urgencia) in force since its publication on 29 May 2025. It added a ground to Citizenship Law 346: a foreigner who proves a relevant investment in the country to the National Migration Directorate can be naturalised, whatever the length of residence.

The decree leaves it to the Economy Ministry to establish which investments count. Decree 524/2025, an ordinary regulatory decree, sets the procedure: the agency the decree created recommends, and the Migration Directorate decides within 30 working days of its report.

Who set the amounts

Türkiye’s amounts sit in the regulation, adopted in 2010 as a Council of Ministers decision. Its footnotes list amendments by presidential decision in 2018, 2022 and 2023, among them Decision 5554, published on 13 May 2022, which raised the property threshold from USD 250,000 to USD 400,000.

Neither Argentine decree contains an amount. The figures come from an Economy Ministry news release of 2 October 2026: a non-refundable USD 350,000 contribution to the National Treasury, or a USD 800,000 public bond created for the programme. A spouse or a single child aged 18 to 25 without children would contribute USD 100,000, and a child under 18 USD 25,000.

The release says applications will open during the fourth quarter of 2026. Searches of the Argentine Official Gazette’s first section from 29 May 2025 to 20 October 2026 found no act defining the relevant investment, fixing the amounts or opening applications. On the sources read, the route is announced, not opened.

What Congress and the courts have done

Decree 366/2025 went to Congress’s Permanent Bicameral Commission. The Senate’s record shows the referral on 10 June 2025 and no date for a committee opinion, and no floor treatment appears in either chamber’s records. Under Law 26,122, article 24, rejection by both chambers repeals a decree, preserving rights acquired while it was in force.

A resolution project in the Chamber of Deputies, 5360-D-2026, asks the chamber to reject the decree and declare it void; it has been referred to committees. Article 194 of Law 27,802, published on 6 March 2026, treats the tax residence of people naturalised under the ground and does not name the decree.

On 30 June 2026 the National Electoral Chamber declared the decree null in one naturalisation case, a residence-based file begun before the decree took effect, citing article 99(3) of the Constitution on legislating by decree. It ordered the ruling notified to federal electoral judges nationwide.

On 21 October 2026 the consolidated text of Law 346 on the government’s legal database still showed the decree’s wording as the current ground.

After a grant

Under Law 5901, article 31 annuls a decision obtained through false declaration or concealment of material facts, and article 32 extends the annulment to the spouse and children who acquired citizenship through that person. Article 33 lets the annulment decision require sale of property in Türkiye within a year, deferred if the person goes to court.

Article 40 withdraws decisions on acquiring or losing citizenship later found to have been taken before the legal conditions were met, or in duplicate. On 4 August 2026 the Interior Ministry reported that 1,413 investors and their families, 6,134 people in all, had their decisions annulled or withdrawn under articles 31 and 40.

For 1,150 investors (5,391 people) conformity certificates were cancelled after inspections found collusive or irregular transactions, and the decisions were annulled. For 263 investors (743 people) the decisions were withdrawn after police and intelligence findings on public order and national security. The ministry describes the matters in the valuation operation as forgery attempts in documents filed before applications.

The Istanbul prosecutor’s investigation is a separate series. Anadolu Agency reported the Justice Minister’s statement of 21 September 2026: the first wave found 687 people who gained citizenship irregularly, and the second wave 1,070, plus 11 whose process was still under way. He said the administrative process to annul had started for both waves.

For Argentina, no official source read says citizenship has been granted under the route, so there is no grant to revoke. The only annulment route found in the texts read is fraud, reported to the Electoral Chamber under Decree 3213/1984. Law 19,549, article 17, bars administrative revocation of a regular act that created rights once it has been notified.

Two bills point in opposite directions, and both are proposed. The Senate’s S-1441/26 would abolish the route and, in article 12, leave unaffected citizenships granted by final acts before it takes effect. The Deputies’ 5254-D-2026 would declare citizenships granted under the ground void and treat pending applications as withdrawn.

A second Deputies bill, 5263-D-2026, would repeal the ground and is silent on granted cases. None of the bills’ records shows a committee opinion or floor step.

This means Türkiye’s exposure lies in how the state applies its statute to files after grant, while Argentina’s lies in the instrument itself: a decree with no floor vote on record, declared null in one case, and the subject of proposed bills that would end the route with different consequences for citizenships already granted.

For Vietnamese citizens

The consolidated Law on Vietnamese Nationality of 24 July 2025 recognises one nationality, Vietnamese, for a Vietnamese citizen unless the Law provides otherwise (article 4). Article 5(4), as amended from 1 July 2025, says that on Vietnamese territory, in dealings with Vietnamese authorities, the State recognises only Vietnamese nationality of a Vietnamese citizen who also holds a foreign one, unless a treaty to which Vietnam is party provides otherwise.

A scoped search of the route texts found no clause excluding Vietnamese nationals in either country. For the property route, purchases by foreigners in Türkiye depend on a Council of Ministers list of 185 countries, which the Your Key Türkiye portal says is not public.

What this article has not established

No official source read gives a demand figure: no count of applications, enquiries or grants in Argentina. No norm giving the terms of the USD 800,000 bond was found.

The Argentine Official Gazette’s first section to 20 October 2026 contains no act defining the relevant investment. The second and third sections were not searched, and the edition of 21 October was not yet published.

The status of the National Electoral Chamber’s ruling before the Supreme Court could not be checked: the court websites did not connect. No text read decides whether Law 19,549 article 17 or Law 26,122 article 24 covers a grant under the decree, or whether Decree 3213/1984 reaches grants made by the Migration Directorate.

Whether the 687 and the 1,070 people are inside the 6,134 is not stated, and no annulment decision for either group is reported. The Interior Ministry statement of 21 September 2026 that Anadolu Agency quotes was not found on the ministry’s website; its text rests on the agency’s report.

Amendments to article 20 of the regulation after 12 December 2023 are not excluded, because the consolidated text read carries no date of its own. Whether Vietnam is on Türkiye’s 185-country property list was not established; Turkish land-registry circulars and any future Argentine agency rules were not read.

Decree 191/2025/NĐ-CP and the other implementing rules of the Vietnamese nationality law were not read, so how Vietnam treats a citizen who acquires a second nationality abroad is not established. No clause requiring renunciation of a prior nationality was found in the Argentine decrees, in Law 5901 or in its regulation.