Foreign Inheritance in Turkey: Guide for International Heirs

Foreign inheritance in Turkey has become a significant legal topic as more expatriates, foreign investors, and dual nationals acquire assets in the country. Whether you are dealing with property, bank accounts, shares, or movable assets, understanding the Turkish inheritance system is crucial for a smooth, compliant, and secure succession process.

At Akkas & Associates Law Firm, we provide full-service legal representation for foreign nationals navigating inheritance, probate, and estate procedures throughout Turkey.

Table of Contents

1. How Turkish Law Applies to Foreign Inheritance
- Key points:
2. Certificate of Inheritance for Foreigners
- Documents required:
3. Recognition of Foreign Wills in Turkey
4. Property Transfer Procedures for Foreign Inheritance
- Steps include:
5. Common Issues Faced by Foreign Heirs in Turkey
- Foreign heirs often encounter:
Step-by-Step Guide to Claiming Your Inheritance
Why Choose Akkas & Associates for Foreign Inheritance Cases?
FAQs on Foreign Inheritance in Turkey
Contact us for Foreign Inheritance in Turkey

Our Istanbul probate lawyers explain how foreign inheritance works in Turkey in 2025, the applicable laws, required documents, common challenges, and how our expert team ensures efficient estate transfers for international clients.

1. How Turkish Law Applies to Foreign Inheritance

The primary law governing inheritance matters in Turkey is the Turkish Civil Code. For foreign nationals, inheritance is determined through a combination of:

The deceased’s national law (applies to movable assets such as bank accounts)
Turkish law (applies to immovable assets such as real estate located in Turkey)

This dual-layer structure means that even if a foreigner leaves a will in another country, Turkish law may still apply to specific assets in Turkey, especially real estate.

Key points:

Foreigners may freely inherit property in Turkey unless restricted by reciprocity or military zones.
Turkish courts may require official translations and apostilles for foreign wills.
Forced heirship rules apply to Turkish properties regardless of the deceased’s nationality.

For a detailed understanding of probate procedures, you may also review our page on probate law in Turkey.

2. Certificate of Inheritance for Foreigners

To begin the inheritance process in Turkey, heirs must obtain a Certificate of Inheritance (Veraset İlamı) from a Turkish Civil Court or Notary. Foreign nationals typically require court-issued certificates because foreign wills and foreign inheritance certificates are not automatically recognized in Turkey.

Documents required:

Death certificate (apostilled)
Passport copies of heirs
Family registry or proof of kinship
Foreign will (if any), notarized and translated
Power of attorney (if represented by a lawyer)

For more information, visit our dedicated service page:
Turkish Certificate of Inheritance.

Turkey imposes inheritance tax on all assets transferred within the country, including those inherited by foreigners. Tax rates vary depending on asset value and relationship to the deceased.

3. Recognition of Foreign Wills in Turkey

Foreign wills are valid in Turkey if they comply with the law of the country where they were executed. However, they still require:

Apostille or consular legalization
Certified Turkish translations
Adaptation into Turkish probate procedures

If a foreign will contradicts Turkish forced heirship rules regarding real estate, the relevant provisions may not be enforceable.

To learn more about will preparation, see our internal resource:
Turkish Will Preparation.

4. Property Transfer Procedures for Foreign Inheritance

Once the Certificate of Inheritance is issued, the heirs can begin the property transfer process at the Land Registry Office.

Steps include:

Payment of inheritance tax
Obtaining property valuations
Title deed transfer applications
Registration of heirs as new owners

When multiple heirs are involved, disputes or partition actions may arise, especially over high-value assets in Istanbul, Antalya, Muğla, and other regions with large foreign populations.

5. Common Issues Faced by Foreign Heirs in Turkey

Foreign heirs often encounter:

Delays in document recognition
Conflicts between foreign wills and Turkish law
Missing or unregistered property records
Disputes among heirs living abroad
Lack of legal representation in Turkey

Our experienced Turkish inheritance lawyers manage all legal, administrative, and translation-related matters to ensure a fast and seamless process.

Step-by-Step Guide to Claiming Your Inheritance

The process for a foreign heir to claim Turkish assets follows a structured legal path. It requires precise documentation and adherence to Turkish court procedures.

1. Obtaining the Death Certificate

The process begins with securing the official death certificate. If the death occurred in Turkey, it will be issued by Turkish authorities. If the death occurred abroad, the foreign death certificate must be:

Apostilled (or legalized) by the relevant authority in the issuing country.
Translated into Turkish by a sworn translator.
Notarized by a Turkish Notary Public.

2. Applying for the Certificate of Inheritance (Veraset İlamı)

This is the most critical legal step. The Certificate of Inheritance is a court order that formally identifies the legal heirs and their respective shares of the deceased’s estate.

For foreign nationals, this certificate must be obtained from a Turkish Civil Peace Court (Sulh Hukuk Mahkemesi). Unlike Turkish citizens, foreign heirs cannot use a Notary Public for this purpose.
The court will require the legalized death certificate, proof of kinship (e.g., birth/marriage certificates, family statements), and the deceased’s details. All foreign documents must be properly legalized and translated.
The court will then apply the relevant inheritance law (Turkish law for real estate, national law of the deceased for movable assets) to issue the certificate.

3. Formal Recognition of a Foreign Will (If Applicable)

If the deceased left a will, it must undergo a process of authentication in the Turkish courts.

A will executed abroad can be valid in Turkey, but its form and content must comply with Turkish legal standards or the law of the place where it was made.
The court will open and read the will, ensuring it adheres to Turkish “reserved portion” rules, which protect the compulsory shares of close relatives like the spouse and children.
For details on the drafting and validity of foreign wills in Turkey, see our comprehensive article on Turkish will preparation.

4. Fulfilling Inheritance Tax Obligations

All assets inherited in Turkey are subject to the Inheritance and Transfer Tax (Veraset ve İntikal Vergisi).

The tax rate is progressive, ranging from 1% to 10% depending on the value of the assets and the degree of kinship between the heir and the deceased.
A foreign heir must obtain a Turkish tax number and file an Inheritance Tax Declaration with the relevant Turkish Tax Office.
Crucially, the inheritance tax must be paid before the final transfer of ownership of the immovable property (title deed transfer) can be completed. Heirs typically have three years to pay the tax in installments.

5. Transferring the Title Deed (Tapu İntikali)

Once the Certificate of Inheritance is issued and the inheritance tax is paid, the heir must apply to the Land Registry Office (Tapu ve Kadastro Müdürlüğü) to officially transfer the ownership of any real estate.

This process, known as Tapu Transfer, requires the heir’s passport, a tax number, the Inheritance Certificate, and the tax clearance document.
The official transfer of the title deed (Tapu) completes the legal acquisition of the property.

6. Registering Other Assets

Movable assets, such as bank accounts and vehicles, must also be officially transferred.

The Certificate of Inheritance is presented to the relevant Turkish bank or institution to release funds or transfer ownership.
Our firm also specializes in complex legal solutions for assets such as company shares and other securities. Learn more about resolving multi-jurisdictional issues by reading our article on Istanbul Probate Lawyers.

7. Recognition and Enforcement of Foreign Judgments

In complex international cases, a foreign court decision regarding the distribution of assets may need to be recognized and enforced in Turkey.

This process is governed by the Turkish Code of International Private and Civil Procedure.
For a foreign judgment to be effective in Turkey, a separate recognition and enforcement lawsuit must be filed in a Turkish court. This is a common requirement, especially when an entire international estate is settled abroad, but includes Turkish real estate.

Why Choose Akkas & Associates for Foreign Inheritance Cases?

Since 1992, our law firm has represented thousands of foreign heirs from Europe, the Middle East, North America, and Asia. We offer:

Full inheritance management
Tax and property transfer services
Court representation for probate matters
Multilingual communication
Support for heirs living abroad

Our team handles every step, allowing heirs to complete inheritance procedures without traveling to Turkey when using a notarized/apostilled Power of Attorney.

FAQs on Foreign Inheritance in Turkey

Q1: Which law applies to a foreign national’s real estate inheritance in Turkey?

A: Regardless of the deceased’s nationality, the inheritance of immovable property (real estate) located in Turkey is always governed by Turkish Civil Law. For all other movable assets, the national law of the deceased generally applies.

Q2: What is a Certificate of Inheritance and why is it mandatory for foreigners?

A: The Certificate of Inheritance (Veraset İlamı or Mirasçılık Belgesi) is a mandatory judicial document issued by a Turkish Civil Peace Court. It officially proves who the legal heirs are and their rightful shares of the estate. It is essential for transferring ownership of any asset in Turkey.

Q3: Do foreign heirs have to pay inheritance tax in Turkey?

A: Yes. Foreign heirs are subject to the Turkish Inheritance and Transfer Tax. The rates are progressive, ranging from 1% to 10%, based on the value of the inherited asset and the kinship degree. This tax must be paid before the official transfer of the title deed can be executed.

Q4: Can a foreign will be used to transfer property in Turkey?

A: Yes, a foreign will can be valid, but it must be authenticated, translated, and legalized. It must also be compliant with Turkish law, particularly the “reserved portion” rules, which protect the mandatory shares of the deceased’s closest relatives.

Q5: Is the inheritance of Turkish real estate subject to forced heirship rules?

A: Yes. Since Turkish law governs the inheritance of real estate located in Turkey, it is subject to the TCC’s forced heirship rules. This means a portion of the estate is legally reserved for mandatory heirs, such as the spouse, children, and parents, even if a will attempts to disinherit them.

Contact us for Foreign Inheritance in Turkey

Foreign inheritance in Turkey requires knowledge of both Turkish law and cross-border succession rules. Whether you are inheriting real estate, bank accounts, assets, or shares, our experienced team at Akkas & Associates Law Firm offers comprehensive and reliable support. For assistance with international probate matters, foreign wills, inheritance certificates, or estate transfers, please contact us today.

If you need support with foreign inheritance in Turkey, Turkish probate for foreigners, international estate planning, or property inheritance procedures, our team is ready to assist you with professional and personalized legal solutions.

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