How Do Turkish Assets Fit Into a Cross-Border Estate?

When a deceased person leaves assets both in Turkiye and abroad, the Turkish assets generally still require a Turkish inheritance procedure, most commonly a Turkish certificate of inheritance and, for real property, title deed transfer through the Turkish land registry. This holds true even where a foreign probate or succession case is already open in another country, because Turkish authorities and registries act on Turkish documentation, not automatically on a foreign court's grant of probate.

A cross-border estate is simply one where the deceased's assets, or the heirs themselves, are spread across more than one country. Turkish law does not treat a foreign probate grant as automatically self-executing over Turkish assets; instead, heirs typically need to obtain recognition or a fresh Turkish determination of heirship (or rely on international private law rules pointing to the applicable succession law) before Turkish banks, the land registry, or other institutions will release or transfer the Turkish assets.

International private law rules determine which country's law governs succession to the deceased's estate as a general matter, but Turkish law specifically reserves Turkish law for immovable property located in Turkiye, regardless of the deceased's nationality or domicile. The Land Registry Law governs how title to Turkish real estate is transferred, including on inheritance, and generally requires either a Turkish certificate of inheritance or an equivalent foreign document that has gone through the appropriate Turkish recognition process. The Turkish Civil Code's inheritance provisions apply to the extent Turkish law governs the succession, whether because of this immovable-property rule or because Turkish law is otherwise the applicable law.

Turkish courts and land registry offices generally require a Turkish certificate of inheritance (veraset ilamı) or a foreign equivalent document processed through the appropriate recognition channel before acting on Turkish real estate or releasing significant Turkish bank assets to heirs. Where a foreign probate case has already determined who the heirs are, Turkish authorities still typically expect this to be reflected in a Turkish-usable document rather than relying directly on the foreign grant, particularly for real property, given the Turkish law rule reserving Turkish law for immovables located in the country.

A frequently discussed issue is how to handle apparent conflicts between what a foreign court decided about the estate as a whole and what Turkish law requires specifically for Turkish immovable property, given that Turkish law can govern the Turkish real estate even where a different law governs the rest of the estate under the general succession rule. Commentators generally treat this as a case of parallel, not necessarily identical, legal regimes applying to different parts of the same estate, which means heirs should expect the Turkish portion to be handled as its own procedure rather than assuming the foreign result simply carries over.

Heirs dealing with a cross-border estate should identify early which Turkish assets exist (real property, bank accounts, vehicles, company shares) and obtain a Turkish certificate of inheritance covering those assets specifically, even if a parallel foreign probate process is also underway. Coordinating the timing of the Turkish and foreign procedures can help avoid inconsistent findings about who the heirs are and in what shares.

There is no single fixed deadline to begin the Turkish inheritance procedure, but delay can leave Turkish assets unmanaged, exposed to disputes among heirs, or subject to tax filing deadlines under Turkish inheritance and transfer tax rules, so prompt action is generally advisable once the death and the Turkish assets are known.

The Turkish certificate of inheritance is typically obtained from the competent Turkish civil court or, in appropriate cases, directly from a Turkish notary. Title deed transfer for real property goes through the relevant land registry directorate once the certificate of inheritance (or its recognised foreign equivalent) is in hand.

• The death certificate, authenticated and translated.
• Documentation identifying all heirs and their relationship to the deceased.
• Any foreign probate grant or determination of heirship already obtained abroad, authenticated and translated.
• Records identifying the specific Turkish assets involved (title deed records, bank account details, company share records).

A common misconception is assuming that a foreign probate grant or a foreign court's determination of heirship will be automatically accepted by Turkish banks and the land registry without any further Turkish procedure. Another mistake is delaying the Turkish procedure until the foreign estate process is fully finished, which can unnecessarily prolong resolution of the Turkish assets and create tax filing complications.

Does a foreign probate grant work directly in Turkiye? Not automatically; a Turkish certificate of inheritance or an appropriately recognised equivalent is generally still needed for Turkish assets.

Can the Turkish and foreign procedures run in parallel? Yes, and this is often the more practical approach rather than waiting for one to finish before starting the other.

Does Turkish law always apply to the whole estate? Not necessarily to the whole estate, but Turkish law specifically applies to immovable property located in Turkiye regardless of what law governs the rest of the estate.

What happens if heirs disagree about the Turkish assets while a foreign case is ongoing? The Turkish inheritance procedure and, if necessary, Turkish partition proceedings address disputes over the Turkish assets specifically, independent of the foreign case's own timeline.

We treat the Turkish portion of a cross-border estate as its own coordinated workstream from the start, obtaining the Turkish certificate of inheritance and handling asset-specific transfers without waiting on the foreign process, while keeping both procedures consistent with each other.