Inheriting assets in Türkiye?
Find the chokepoint.
The single thing that traps foreign heirs is the title and governing-law chokepoint — which law applies, and why a foreign probate cannot move Turkish title. This maps it in a minute, then shows you the documents you'll need. In plain English, no figures, no obligation.
This is a guide, not legal advice or a valuation. It won't put a number on your estate — it maps which law governs and the documents you'll need.
How a foreigner inherits Turkish assets
For foreign heirs and owners, almost everything turns on one chokepoint: which law governs the estate, and what document a Turkish authority will accept before it releases an asset or transfers title. Get that right and the rest is largely paperwork. Get it wrong and a foreign probate sits unused.
- Which law governs (MÖHUK 5718 art. 20): Türkiye's private international law splits succession. Immovable property in Türkiye — land and buildings — is governed by Turkish succession law, whatever the deceased's nationality, including forced heirship and the protected reserved share (saklı pay) under the Civil Code (TMK) that a will cannot override. Movable assets, such as bank balances and shares, generally follow the deceased's national law — but are still collected through the Turkish estate process.
- Why a foreign probate can't transfer title: a foreign inheritance certificate or grant of probate, even apostilled and translated, generally cannot move Turkish title on its own. You need a Turkish certificate of inheritance (veraset ilamı / mirasçılık belgesi). Where an heir is a foreign national, it is usually obtained from the civil court of peace (sulh hukuk mahkemesi), not a notary.
- Where heirs disagree: if co-owners cannot agree on a jointly inherited property, a partition action (izale-i şuyu) may be needed to divide or sell it.
The apostille document checklist. To run the process from abroad, foreign-language documents must be authenticated and translated. You will usually need: the death certificate; documents proving heirship (birth and marriage records); the deceased's ID or passport; and the will, if any — each apostilled under the Hague Convention (or consular-legalised where the apostille does not apply), then given a sworn Turkish translation (yeminli tercüme). A power of attorney (vekaletname), signed before a notary and apostilled or signed at a Turkish consulate, lets a Turkish lawyer act for you without you travelling.
The deliverable here is an avukat-run succession — obtaining the certificate of inheritance, handling the tax step, and completing the title transfer (tapu) and account release. It is not a tool that drafts or generates a will; preparing a valid will and issuing the certificate are reserved acts under Turkish law. For the full route, see our guide on inheritance and estate recovery in Türkiye for foreign heirs.
Common questions
Can my home-country probate transfer Turkish title?
Usually not on its own. For Turkish real estate and Turkish bank accounts, the land registry and banks generally require a Turkish certificate of inheritance (veraset ilamı / mirasçılık belgesi) — even if your foreign grant of probate is apostilled and translated. A foreign will or court decision may still be relevant, but it often needs a recognition step in Türkiye first.
What is saklı pay (the reserved share)?
For estates governed by Turkish law, close heirs — such as a spouse and children — have a protected minimum share of the estate, the reserved share (saklı pay) under the Civil Code (TMK). A will is honoured only up to those limits, so it generally cannot fully disinherit a protected heir of Turkish immovable property.
Do I need to come to Türkiye?
Usually no. The process can generally be run remotely through a power of attorney (vekaletname) that you sign before a notary and have apostilled, or sign at a Turkish consulate. A Turkish lawyer can then file for the certificate, deal with the tax office, and complete the transfers on your behalf.
Which documents must be apostilled?
Typically the death certificate, documents proving heirship (birth and marriage records), the deceased's ID or passport, the will if any, and the power of attorney. Each is apostilled under the Hague Convention — or consular-legalised where the apostille does not apply — and then given a sworn Turkish translation (yeminli tercüme). The exact list depends on your facts.
Rather just ask a person?
Tell us who died, what's in Türkiye and what documents you hold — and get an honest view in English of the route and the next step.