How Is the Estate of a Foreigner Who Dies in Türkiye Distributed?

When a foreign national dies while living in Türkiye—or dies abroad while owning assets in Türkiye—the inheritance process can involve more than one legal system.

The deceased may have:

• an apartment in Istanbul;
• a villa in Antalya;
• land in Muğla;
• Turkish bank accounts;
• vehicles;
• shares in a Turkish company;
• valuable movable property;
• debts;
• investments;
• cryptocurrency;
• business receivables;
• or assets in several different countries.

The deceased may also leave:

• a surviving spouse;
• children;
• children from an earlier marriage;
• parents;
• siblings;
• heirs living abroad;
• a foreign will;
• or no identifiable heirs at all.

The first question in such a case is therefore not simply:

“Who are the heirs?”

The more important legal question is:

“Which country’s inheritance law applies to each part of the estate?”

Under Article 20 of Turkish International Private and Procedural Law No. 5718, the general rule is that succession is governed by the national law of the deceased.

However, there is a major exception:

Turkish law applies to immovable property located in Türkiye.

Article 20 also provides that rules concerning the opening, acquisition and division of an estate are governed by the law of the country where the estate property is located.

This means that the estate of a foreigner can potentially be governed by different laws for different assets.

For example:

A British citizen dies owning:

• an apartment in Bodrum;
• a Turkish bank account;
• securities in London;
• and a house in England.

The Turkish apartment is subject to Turkish inheritance law because it is immovable property situated in Türkiye.

The treatment of movable assets, such as bank funds, may require application of the deceased’s national inheritance law together with Turkish rules governing the acquisition and administration of assets located in Türkiye.

The English property will generally need to be dealt with through the legal system applicable there.

International inheritance cases therefore often require a multi-jurisdictional estate strategy rather than a single inheritance procedure.

Short Answer

If a foreign national dies leaving assets in Türkiye:

• the deceased’s national law generally governs succession;
• Turkish law governs immovable property located in Türkiye;
• Turkish rules also govern important aspects of opening, acquiring and dividing estate assets situated in Türkiye;
• heirs may need a Turkish certificate of inheritance — mirasçılık belgesi / veraset ilamı;
• Turkish real estate can generally pass by inheritance to foreign heirs;
• inheritance tax may apply to property situated in Türkiye regardless of the nationality of the deceased or heir;
• debts must be checked before the inheritance is accepted;
• where Turkish law applies, heirs generally have a three-month period to reject inheritance;
• and wills may need to be examined under both Turkish conflict-of-laws rules and the deceased’s national law.

A foreign heir should therefore not transfer, divide or dispose of Turkish assets until the applicable law and inheritance documents have been determined.

Which Country’s Inheritance Law Applies When a Foreigner Dies?

The starting point is Article 20 of Law No. 5718.

It provides three particularly important rules.

Rule 1: Succession Is Generally Governed by the Deceased’s National Law

If the deceased was a German citizen, German inheritance law may therefore be relevant.

If the deceased was Iranian, Iranian succession rules may need to be examined.

If the deceased was British, the applicable national-law analysis may involve the relevant legal system within the United Kingdom depending on the deceased’s legal connection and internal rules.

The Turkish judge is required to apply Turkish conflict-of-laws rules and, when those rules designate foreign law, to apply that foreign law ex officio.

Foreign law is therefore not simply an optional argument raised by the parties.

Rule 2: Turkish Law Applies to Immovable Property Located in Türkiye

This is the most important exception for foreign property owners.

Article 20/1 expressly states:

Turkish law applies to immovable property located in Türkiye.

Accordingly, when a foreigner dies owning:

• an apartment;
• house;
• villa;
• land;
• commercial unit;
• agricultural property;
• or another immovable property

in Türkiye, Turkish inheritance law becomes directly relevant to that property.

This can produce a different inheritance result from the rules governing the deceased’s movable assets abroad.

Example: Foreign Citizen Owns a Villa in Antalya

Assume a German citizen dies leaving:

• a spouse;
• two children;
• and a villa in Antalya.

For the Antalya villa, Turkish inheritance law applies.

Under the Turkish Civil Code:

• descendants are first-degree statutory heirs;
• children inherit equally;
• and a surviving spouse who inherits together with descendants receives one quarter of the estate subject to Turkish law.

Therefore, if there is no valid testamentary arrangement changing the disposable portion:

• surviving spouse: 1/4
• two children together: 3/4
• each child: 3/8

This example concerns the Turkish immovable property.

The foreigner’s other assets may require a separate applicable-law analysis.

Rule 3: The Location of Estate Assets Matters for Opening, Acquisition and Division

Article 20/2 provides that rules concerning:

• opening of the inheritance;
• acquisition of the inheritance;
• and division of the estate

are governed by the law of the country where the relevant estate is situated.

This is highly important in practice.

Even when foreign substantive succession law determines who the heirs are for certain movable assets, the actual transfer of:

• Turkish bank funds;
• Turkish registered vehicles;
• Turkish company interests;
• Turkish real property;

will still involve Turkish procedural, registration and estate-administration requirements.

Does It Matter Whether the Foreigner Died in Türkiye or Abroad?

Yes, but not because the place of death automatically determines the inheritance shares.

A foreigner can die:

• in Türkiye;
• in their country of nationality;
• or in a third country

and still leave an estate in Türkiye.

The location of death becomes especially relevant for:

• obtaining the death certificate;
• inheritance tax filing periods;
• civil-status documentation;
• international legalisation;
• and practical estate administration.

For example, Turkish inheritance-tax filing deadlines vary depending on:

• whether death occurred in Türkiye or abroad;
• and where the heirs are located.

The Turkish Revenue Administration currently provides different periods ranging from four to eight months depending on these circumstances.

Which Turkish Court Has Jurisdiction Over the Estate of a Foreign Deceased?

Article 43 of Law No. 5718 contains a special international jurisdiction rule for inheritance cases.

Inheritance proceedings are heard:

1. before the court of the deceased’s last domicile in Türkiye; or
2. if the deceased had no last domicile in Türkiye, before the court where assets belonging to the estate are located.

This is particularly useful when the foreigner lived abroad but owned Turkish assets.

For example:

A British national lived permanently in England but owned an apartment in Alanya.

A Turkish inheritance proceeding may be brought in the Turkish court connected to the location of the estate property.

The Court of Cassation has repeatedly applied this rule in foreign-element inheritance proceedings.

Most recently, the 5th Civil Chamber, in its 2 March 2026 decision numbered E. 2025/13170, K. 2026/3621, held that where a foreign deceased had no Turkish last domicile but had estate assets in Mersin, the competent Turkish court was the relevant Mersin Civil Court of Peace.

This recent decision is particularly useful because it confirms that Article 43 remains central in foreign inheritance certificate proceedings.

What Is an Inheritance Certificate in Türkiye?

An inheritance certificate is known in Turkish as:

mirasçılık belgesi

or traditionally:

veraset ilamı.

It identifies:

• who the legal heirs are;
• and their respective inheritance shares.

Article 598 of the Turkish Civil Code permits inheritance certificates to be issued to statutory heirs.

The current statutory framework also recognises issuance through courts and, in appropriate ordinary cases, notaries. Recent Court of Cassation jurisprudence expressly refers to both courts and notaries under Article 598.

However, foreign inheritance cases frequently require a Civil Court of Peace — Sulh Hukuk Mahkemesi proceeding because:

• the deceased is foreign;
• civil registry information is abroad;
• the heirs are foreign;
• foreign law must be established;
• foreign marriage or birth documents must be examined;
• or Turkish real estate is involved.

In complex international estates, a court-issued certificate is often the more appropriate route.

Can a Foreign Inheritance Certificate Be Used Directly in Türkiye?

Not always.

This is a particularly important issue for foreign heirs.

The General Directorate of Land Registry and Cadastre states that inheritance transfers involving foreign natural persons are made on the basis of:

• inheritance certificates issued by Turkish courts;
• or certificates issued by competent foreign authorities and validated in accordance with Turkish legal requirements by Turkish courts.

TKGM therefore states that, as a general rule, a foreign inheritance certificate should not simply be assumed to be directly sufficient for Turkish land registry transfer without the necessary Turkish legal recognition or confirmation procedure, subject to any applicable international treaty.

This means that heirs should not merely arrive at the Turkish Land Registry Office with a foreign probate document and assume title will automatically be transferred.

What Documents May Be Needed to Obtain a Turkish Inheritance Certificate?

International inheritance files commonly require documents such as:

• official death certificate;
• passport or identity record of the deceased;
• nationality certificate where necessary;
• birth certificates of heirs;
• marriage certificate;
• divorce documents where relevant;
• records concerning deceased children;
• civil registry/family registry extracts;
• adoption records where applicable;
• foreign inheritance certificate;
• will;
• foreign court decisions;
• documents establishing family relationship;
• documents identifying Turkish estate property.

Foreign public documents may require:

• an apostille;
• consular legalisation where the Apostille Convention does not apply;
• and certified Turkish translation.

The exact requirements depend on:

• country of issue;
• applicable international treaties;
• nature of the document;
• and the Turkish authority before which the document will be used.

What Happens to Turkish Real Estate Owned by a Foreign Deceased?

Foreign heirs can generally acquire Turkish real estate through inheritance.

TKGM expressly confirms that transfer of Turkish real property to foreign natural persons through succession is possible.

This is an important distinction from ordinary voluntary purchases.

Foreign acquisition restrictions do not necessarily prevent the inheritance from first passing to the heir.

TKGM explains that the inheritance transfer is generally carried out first, and the foreign heir’s eligibility to continue holding the property is then examined under the applicable restrictions.

Can Every Foreign Heir Keep the Turkish Property?

Not necessarily.

This is where foreign-property restrictions become important.

Under the Turkish Land Registry framework, foreign natural persons are subject to statutory limitations concerning ownership of Turkish real estate.

TKGM states that where inherited property:

• lies in an area where the foreign person is not permitted to retain ownership;
• or the foreign heir’s nationality falls outside the countries permitted to own Turkish real estate under the applicable framework,

the inheritance can still initially be transferred, but the foreign heir may thereafter be required to dispose of the property.

If it is not disposed of, liquidation procedures may follow.

Therefore:

right to inherit ≠ unlimited right to retain every Turkish property indefinitely.

This distinction is important.

Example: Foreign Heir Cannot Normally Acquire Property in the Relevant Location

A foreign national inherits land in Türkiye from a deceased parent.

The heir’s nationality or the location of the land creates a statutory foreign-ownership restriction.

The correct approach is not necessarily:

“The foreigner is not an heir.”

Instead, Turkish Land Registry practice recognises the inheritance and then evaluates whether the foreign person may legally retain the asset.

If not, disposal or liquidation requirements can arise.

Can Foreign Heirs Sell the Inherited Property?

Generally yes, subject to completion of inheritance and land registry procedures.

After title is transferred to the heirs, they may potentially:

• keep the property;
• sell it;
• divide it;
• transfer shares among heirs;
• or undertake another lawful transaction.

Where ownership restrictions prevent continued retention, sale may in fact become necessary.

Foreign heirs should therefore obtain the inheritance certificate and complete tax/registry procedures before planning a sale.

How Are Turkish Real Estate Shares Distributed If Turkish Law Applies?

Under the Turkish Civil Code, descendants form the first line of statutory heirs.

Children inherit equally.

If a child died before the deceased, that child’s descendants generally take the child’s place by representation.

The surviving spouse’s share depends on which relatives survive.

Under Article 499:

Spouse + Children

Spouse receives:

1/4

Descendants receive:

3/4

Spouse + Parents or Their Descendants

Spouse receives:

1/2

The parent line receives:

1/2

Spouse + Grandparent Line

Spouse receives:

3/4

Relevant relatives receive:

1/4

No Relevant Blood Relatives

The surviving spouse receives:

the entire inheritance.

These rules are particularly important for immovable property in Türkiye because Turkish law applies directly to such assets under MÖHUK Article 20.

Does a Foreign Spouse Have the Same Inheritance Rights as a Turkish Spouse?

Where Turkish inheritance law governs the relevant asset, foreign nationality does not by itself remove the surviving spouse’s statutory inheritance position.

The key questions are:

• was there a legally valid marriage at the date of death?
• had the marriage been dissolved by a final divorce?
• is the surviving person legally recognised as the spouse?

If yes, the spouse can benefit from the statutory share under Turkish law where Turkish succession rules apply.

The spouse does not need to become a Turkish citizen merely to qualify as the deceased’s surviving spouse.

What Happens If the Deceased Was in the Middle of a Divorce?

This requires separate legal analysis.

The status of the marriage at the time of death can substantially affect inheritance rights.

If the divorce had already become final before death, the former spouse is ordinarily no longer a surviving spouse for inheritance purposes.

If divorce proceedings were still pending, special Turkish Civil Code rules concerning continuation of certain divorce issues after death may become relevant, particularly where Turkish law governs.

International divorce and succession law may interact, so the actual procedural status of the marriage must be reviewed carefully.

Can Children from a Previous Marriage Inherit?

Yes, where they are legally established descendants and the relevant succession law recognises them.

Under Turkish law, descendants are first-line statutory heirs and children inherit equally.

The fact that one child was born from:

• a previous marriage;
• the current marriage;
• or another legally established parent-child relationship

does not automatically make that child inferior to another descendant.

Under Turkish law, legally established children inherit within the descendant class.

What Happens If There Is a Will?

The existence of a will can significantly alter the estate.

But an international will raises several separate questions:

1. Was the deceased legally capable of making the will?
2. Was the will executed in a legally valid form?
3. Which law governs the testament?
4. Does Turkish law protect mandatory or reserved heirs regarding Turkish real estate?
5. Has the foreign will been opened or recognised through the appropriate procedure?

MÖHUK Article 20 specifically regulates wills and other dispositions upon death.

It provides that the form of a disposition upon death can be valid under the relevant conflict-of-laws rules and that a disposition complying with the deceased’s national law can also be valid.

Capacity to make a testamentary disposition is governed by the deceased’s national law at the time the disposition was made.

Accordingly, a will written abroad is not automatically invalid in Türkiye merely because it was not written before a Turkish notary.

Can a Foreign Will Transfer a Turkish Property to One Person?

Potentially, yes—but the will cannot be analysed independently of Turkish mandatory inheritance rules where Turkish law governs the property.

Turkish succession law recognises reserved shares — saklı pay for certain heirs.

Under Article 506 of the Turkish Civil Code, reserved shares currently include:

• descendants: one half of their statutory inheritance share;
• each parent: one quarter of their statutory inheritance share;
• surviving spouse: depending on the surviving heir class, the statutory proportions protected by Article 506.

Therefore, where Turkish law applies to a Turkish immovable, a will leaving the entire property to one beneficiary may potentially be subject to reduction claims if it infringes protected reserved shares.

Example: Foreign Owner Leaves Entire Istanbul Apartment to a Friend

A foreign national owns an apartment in Istanbul.

The deceased has:

• a spouse;
• two children;
• and a foreign will leaving the apartment entirely to a friend.

Because the apartment is immovable property located in Türkiye, Turkish succession law applies.

The foreign will may be formally valid, but the surviving protected heirs may potentially have reserved-share claims under Turkish law.

Thus:

valid will ≠ unlimited ability to defeat all statutory protected inheritance rights.

What Happens If There Is No Will?

Where no valid testamentary disposition governs the asset, statutory succession rules apply.

For Turkish immovable property, Turkish statutory heir rules will determine succession.

For other assets, the deceased’s national inheritance law may determine the heirs and their shares, subject to MÖHUK Article 20 and the rules governing estate assets situated in Türkiye.

This is why the Turkish inheritance certificate in a foreign estate can be more complicated than a purely domestic certificate.

The court may need to:

• determine foreign law;
• examine foreign civil-status records;
• and separate Turkish real estate from other assets.

What Happens to Turkish Bank Accounts?

Turkish bank accounts are usually among the most important practical estate assets.

The funds are movable property rather than immovable property.

Accordingly, the applicable succession law cannot automatically be determined by using the special Turkish-immovable rule.

The deceased’s national law may determine substantive heirship, while Turkish rules govern important issues concerning the acquisition, administration, proof of heirship and release of the account situated in Türkiye.

Banks typically require documentation such as:

• death certificate;
• inheritance certificate;
• identity documents;
• Turkish tax documentation;
• and other compliance documents

before releasing estate funds.

The exact process can differ depending on the bank and the international structure of the estate.

Can One Heir Withdraw the Entire Turkish Bank Account?

Not merely because that person is a child or spouse of the deceased.

The bank needs to establish:

• who the legal heirs are;
• their shares;
• whether estate tax requirements are satisfied;
• and whether the heirs jointly authorise a transaction or an individual entitlement exists.

A family member should not assume that possessing:

• the deceased’s bank card;
• password;
• telephone;
• or online banking credentials

creates a legal right to withdraw estate funds after death.

Unauthorised post-death withdrawals can create serious civil and potentially criminal disputes among heirs.

What Happens to Turkish Company Shares?

A deceased foreign national may own:

• limited company shares;
• joint stock company shares;
• partnership interests;
• or other commercial rights in Türkiye.

Inheritance of these interests can involve both:

• succession law;
• and Turkish corporate law.

The heirs must determine:

• the deceased’s shareholding;
• company type;
• articles of association;
• shareholders’ agreements;
• Trade Registry records;
• restrictions on transfer;
• and how the inherited interest must be registered.

The fact that an heir inherits a company interest also does not automatically give a foreign heir the right to personally work in Türkiye.

Company ownership and work authorisation are separate matters.

What Happens to Vehicles in Türkiye?

Vehicles registered in the deceased’s name form part of the Turkish estate.

Transfer normally requires:

• inheritance documentation;
• tax procedures;
• and registration formalities.

If several heirs inherit the vehicle, they must decide whether:

• to remain co-owners;
• sell it;
• or transfer it to one heir under an agreement.

Specific tax issues can arise for vehicles originally acquired under exemptions, so special-status vehicles should be reviewed individually.

Do Heirs Also Inherit the Deceased’s Debts?

Yes, potentially.

Inheritance is not limited to assets.

Under Article 599 of the Turkish Civil Code, where Turkish succession law applies, heirs acquire the estate as a whole upon death and can also become responsible for the deceased’s debts.

This makes debt investigation critical.

Before accepting an estate, heirs should investigate:

• bank loans;
• mortgages;
• unpaid tax;
• credit cards;
• enforcement proceedings;
• company guarantees;
• rent debt;
• litigation;
• private loans;
• and other liabilities.

A valuable Turkish apartment does not necessarily mean the estate has positive net value.

Can a Foreign Heir Reject the Inheritance?

Where Turkish rejection rules apply, yes.

The Turkish Civil Code permits legal and appointed heirs to reject inheritance.

Article 606 establishes a general three-month period.

For statutory heirs, the period generally begins when they learn of the death and their heirship unless later knowledge can be proven.

For an heir appointed by testament, the period generally begins when the testamentary appointment is formally notified.

This deadline can be particularly dangerous for foreign heirs because:

• they may live abroad;
• they may learn about Turkish assets late;
• documents may take months to obtain;
• and they may not realise Turkish debts exist.

Immediate estate investigation is therefore important.

Is Inheritance Automatically Rejected If the Estate Is Insolvent?

Turkish law contains a special rule.

Article 605 provides that where the deceased’s insolvency was clearly evident or officially established at death, the inheritance can be deemed rejected under the statutory conditions.

However, heirs should not casually rely on this rule.

Whether an estate qualifies for deemed rejection — hükmen ret can become a disputed issue requiring litigation.

Where substantial debts exist, legal advice should be obtained before heirs:

• dispose of estate property;
• withdraw funds;
• or take actions that could be interpreted as unconditional acceptance.

Is There Inheritance Tax in Türkiye?

Yes.

Türkiye applies Inheritance and Transfer Tax — Veraset ve İntikal Vergisi.

Importantly, the Turkish Revenue Administration states that property located in Türkiye falls within inheritance and transfer tax regardless of nationality.

Therefore, property located in Türkiye can be taxable even where:

• the deceased is foreign;
• the heir is foreign;
• and both individuals normally live outside Türkiye.

This is particularly relevant for:

• Turkish real estate;
• bank funds;
• and other Turkish estate assets.

What Are the 2026 Turkish Inheritance Tax Rates?

For 2026, inheritance transfers are subject to a progressive tax tariff.

The current rates are:

• first TRY 3,000,000: 1%
• next TRY 7,000,000: 3%
• next TRY 15,000,000: 5%
• next TRY 30,000,000: 7%
• portion exceeding TRY 55,000,000: 10%.

These rates apply to the taxable inheritance base after considering relevant deductions and exemptions.

They should not be confused with much higher rates applicable to certain gratuitous transfers made outside inheritance.

What Are the 2026 Inheritance Tax Exemptions?

For 2026, the Revenue Administration publishes the following key inheritance exemptions:

For each:

• child, including qualifying adopted descendants;
• and surviving spouse,

the inheritance-share exemption is:

TRY 2,907,136.

Where the surviving spouse is the sole heir, the exemption is:

TRY 5,817,845.

These figures change annually.

Therefore, older online articles may contain outdated amounts.

Is an Inheritance Tax Return Required If No Tax Will Be Payable?

Yes, in inheritance cases.

The Revenue Administration specifically states that an inheritance tax return is required even where the inherited assets are below the applicable exemption threshold.

This is an important practical point.

Heirs should not conclude:

“The inheritance is below the tax exemption, therefore we do not need to file anything.”

The exemption and the filing obligation are separate questions.

When Must the Inheritance Tax Return Be Filed?

The filing period depends on where the death occurred and where the heirs are located.

According to current Revenue Administration guidance:

Death Occurred in Türkiye

If heirs are in Türkiye:

4 months

If heirs are abroad:

6 months

Death Occurred Abroad

If heirs are in Türkiye:

6 months

If heirs are in the same foreign country where the deceased died:

4 months

If heirs are in another foreign country:

8 months.

International heirs should therefore calculate the deadline immediately after becoming aware of the death.

How Is Turkish Inheritance Tax Paid?

Current Revenue Administration guidance states that inheritance tax is generally paid over three years, in six equal instalments, payable in May and November.

This makes Turkish inheritance tax different from systems requiring the full tax to be paid immediately.

However, particular estate transactions may still require tax-clearance procedures before assets can be fully transferred or released.

Can Debts Be Deducted for Inheritance Tax Purposes?

Potentially, yes.

The Revenue Administration states that documented debts of the deceased, including qualifying tax debts, can be deducted when calculating the inheritance-tax base.

Certain funeral and death-announcement expenses may also qualify.

Valid documentation is essential.

Heirs should therefore retain:

• loan statements;
• tax debt records;
• mortgage documents;
• invoices;
• funeral expenses;
• and other evidence of deductible liabilities.

What Happens If a Foreign Heir Later Sells an Inherited Turkish Property?

An important Turkish tax advantage may apply.

The Revenue Administration states that gains from selling property acquired through inheritance are generally not treated as taxable capital appreciation gains under the ordinary five-year disposal rule.

GİB provides the example of an apartment acquired by inheritance and later sold, explaining that the resulting gain is outside ordinary value-increase taxation because acquisition occurred through inheritance.

Other taxes and transaction costs can still arise when selling.

But this distinction can be important when planning disposal of inherited Turkish property.

What Happens If There Are No Heirs?

MÖHUK Article 20/3 expressly provides:

An heirless estate located in Türkiye passes to the Turkish State.

This rule is particularly important where:

• the foreign deceased has no identifiable family;
• no valid appointed heir exists;
• or all inheritance rights fail under the applicable legal framework.

The existence of potential foreign relatives should therefore be investigated carefully before an estate is treated as heirless.

Can the Turkish Court Protect the Estate Before the Heirs Are Identified?

Yes.

Turkish law permits the Civil Court of Peace to take measures necessary to preserve estate property and ensure eventual transfer to rightful heirs.

The Court of Cassation has applied these principles in foreign-estate cases involving property located in Türkiye.

Protective measures may become particularly important where:

• the deceased lived alone;
• Turkish property is vacant;
• rental income continues;
• company operations must be protected;
• valuables could disappear;
• or the heirs live abroad and cannot immediately take control.

Can a Foreign Heir Handle the Turkish Estate Without Traveling to Türkiye?

Often, yes.

A foreign heir may grant an appropriate Turkish power of attorney.

Depending on the procedures required, a Turkish lawyer may then assist with:

• inheritance certificate proceedings;
• tax applications;
• Land Registry procedures;
• bank correspondence;
• estate litigation;
• property sale;
• company-share procedures;
• and other estate matters.

A foreign power of attorney may require:

• apostille or consular legalisation;
• certified translation;
• and specific authority for particular transactions.

For real estate sales and inheritance transactions, power-of-attorney wording should be prepared carefully.

Example 1: British Citizen Dies Owning an Apartment and Bank Account in Türkiye

A British citizen lives in the UK and owns:

• an apartment in Alanya;
• TRY 2 million in a Turkish bank.

He leaves:

• wife;
• two children.

For the apartment:

Turkish inheritance law applies.

For the bank account:

the deceased’s national succession law and Turkish rules concerning estate acquisition and administration must be analysed together.

Because the deceased had no last residence in Türkiye, inheritance proceedings concerning Turkish assets can be brought where estate assets are located under MÖHUK Article 43.

The heirs may need:

• Turkish inheritance certificate;
• inheritance tax return;
• Land Registry transfer;
• bank release documentation.

Example 2: Russian Citizen Dies While Living in Antalya

A Russian citizen permanently lives in Antalya and dies there.

The person owns:

• Antalya villa;
• Turkish bank deposits;
• car;
• Russian property.

The Turkish villa is governed by Turkish inheritance law.

The remaining estate requires asset-by-asset conflict-of-laws analysis.

Because the deceased’s last Turkish domicile was Antalya, Turkish inheritance proceedings will generally be centred there under Article 43.

Example 3: Foreign Deceased Leaves a Turkish Apartment Entirely to One Child

A foreign father has:

• wife;
• three children;
• apartment in Istanbul.

A foreign will leaves the entire Istanbul apartment to one child.

Turkish law applies to that apartment.

The will must therefore be examined not only for formal validity but also for possible infringement of the reserved shares of protected heirs.

The spouse and other descendants may potentially have reduction claims under Turkish law.

Example 4: Foreign Heir Inherits Property but Cannot Legally Retain It

A foreign national inherits Turkish real estate.

The inheritance is registered.

However, the heir falls within a nationality or location-based ownership restriction.

TKGM guidance indicates that inheritance transfer can occur first, but the heir may subsequently be required to dispose of the asset; otherwise liquidation can follow.

The heir should therefore check eligibility before deciding to retain the property indefinitely.

Example 5: Estate Has More Debt Than Assets

A foreigner dies leaving:

• TRY 1 million bank debt;
• credit-card debts;
• tax liabilities;
• a vehicle worth TRY 400,000.

The foreign heirs should not focus only on inheriting the car.

If Turkish inheritance law governs the relevant estate and the inheritance is accepted, estate debts can also pass to heirs.

The three-month rejection period may become critical.

Example 6: Foreign Inheritance Certificate Exists Abroad

The heirs obtain a probate or inheritance certificate from the deceased’s home country.

They take it directly to the Turkish Land Registry.

The document may not automatically be enough.

TKGM states that foreign inheritance documents generally need to satisfy the Turkish judicial confirmation framework for Turkish inheritance transfer unless an applicable international treaty provides otherwise.

The heirs should therefore determine the Turkish recognition/certificate procedure before arranging the title transfer.

Frequently Asked Questions

Which law applies when a foreigner dies in Türkiye?

The general rule is the deceased’s national law.

Does Turkish law ever apply?

Yes. Turkish law applies to immovable property situated in Türkiye.

Does it matter where the deceased died?

It affects procedure, documentation and inheritance tax deadlines, but the place of death alone does not determine all inheritance shares.

Can a foreign spouse inherit property in Türkiye?

Yes, where the spouse is a legal heir under the applicable inheritance law.

Can foreign children inherit Turkish property?

Yes.

Can a foreigner inherit a Turkish apartment?

Yes. TKGM expressly confirms inheritance transfer to foreign natural persons is possible.

Can every foreign heir keep inherited Turkish real estate indefinitely?

Not necessarily. Nationality and location restrictions may require later disposal.

What inheritance share does a surviving spouse receive under Turkish law?

With descendants: 1/4.

With the parent line: 1/2.

With the grandparent line: 3/4.

If none of those heirs exist: the entire inheritance.

Do children inherit equally under Turkish law?

Yes. Children are equal descendants for statutory succession.

Does Turkish law always govern the foreigner’s bank account?

Not automatically. Movable assets require application of MÖHUK Article 20’s general and estate-location rules.

Do heirs need a Turkish inheritance certificate?

Frequently yes, particularly for Turkish registered assets.

Can a Turkish court issue an inheritance certificate for foreign heirs?

Yes.

Recent 2026 Court of Cassation jurisprudence confirms jurisdiction of Turkish Civil Courts of Peace in foreign-element inheritance certificate cases where estate assets are located in Türkiye.

Can a foreign inheritance certificate be used directly?

Not always. Turkish confirmation may be required, subject to treaties.

Does a foreign will work in Türkiye?

Potentially yes. MÖHUK Article 20 contains rules recognising testamentary dispositions satisfying applicable formal requirements or the deceased’s national law.

Can a will remove children entirely from Turkish real estate inheritance?

Not always. Reserved-share rules may protect descendants where Turkish law applies.

Do heirs inherit debts?

Potentially yes.

Can inheritance be rejected?

Yes, where Turkish rejection rules apply.

How long is the rejection period?

Generally three months.

Is there Turkish inheritance tax?

Yes.

Does inheritance tax apply when both deceased and heir are foreigners?

Turkish assets can be within the tax system regardless of nationality.

What are the 2026 inheritance tax rates?

They range progressively from 1% to 10%.

What is the 2026 exemption for a spouse or child?

TRY 2,907,136 per qualifying spouse/descendant inheritance share.

If a surviving spouse is the sole heir, the exemption is TRY 5,817,845.

Must an inheritance tax return be filed even below the exemption?

Yes.

What happens if no heirs exist?

Estate property situated in Türkiye ultimately passes to the Turkish State under MÖHUK Article 20/3.

A Practical Step-by-Step Process for Foreign Heirs

Step 1 — Obtain the Death Certificate

Determine:

• country of death;
• date of death;
• nationality of deceased.

Step 2 — Identify Every Asset

Search for:

• Turkish real estate;
• bank accounts;
• company shares;
• vehicles;
• investments;
• receivables;
• debts.

Step 3 — Separate Immovable and Movable Assets

This is essential for applicable-law analysis.

Step 4 — Determine the Deceased’s National Law

For non-Turkish immovable assets and movable inheritance questions, foreign succession law may need to be established.

Step 5 — Obtain Family/Civil Status Documents

Establish:

• spouse;
• descendants;
• parents;
• other potential heirs.

Step 6 — Check for a Will

Determine:

• where it was made;
• under which law;
• whether formally valid;
• whether it affects Turkish reserved shares.

Step 7 — Obtain a Turkish Inheritance Certificate

Particularly where Turkish assets must be transferred.

Step 8 — Check Debts Before Acceptance

Do not overlook the three-month rejection period.

Step 9 — File the Turkish Inheritance Tax Return

Calculate the correct deadline according to:

• place of death;
• heir’s location.

Step 10 — Transfer Turkish Assets

Complete:

• Land Registry;
• bank;
• vehicle;
• company;
• and other registration procedures.

Step 11 — Check Foreign Ownership Restrictions

If a foreign heir receives Turkish real estate, verify whether the property can legally be retained.

Step 12 — Coordinate Foreign Estate Proceedings

Turkish proceedings may not resolve:

• houses abroad;
• foreign bank accounts;
• foreign securities;
• other overseas estate assets.

The Most Important Mistake: Treating the Entire Estate as Though One Country’s Law Automatically Applies

International inheritance rarely works that simply.

Consider a deceased foreign national owning:

• apartment in Türkiye;
• bank account in Türkiye;
• apartment in France;
• brokerage account in the United States.

It would be incorrect to assume:

“The deceased died in Türkiye, therefore Turkish law governs everything.”

It would also be incorrect to assume:

“The deceased was French, therefore French law governs everything.”

Turkish MÖHUK creates a more sophisticated system.

The deceased’s national law is the general starting point.

But Turkish immovable property is governed by Turkish law.

Opening, acquisition and division of estate property also depend on where that estate property is situated.

International heirs therefore need an asset map before attempting distribution.

Conclusion: A Foreigner’s Estate in Türkiye Must Be Analysed Asset by Asset

When a foreign national dies with property or financial interests in Türkiye, inheritance cannot safely be handled by simply applying the deceased’s home-country succession rules to everything.

Article 20 of Law No. 5718 creates the fundamental framework.

The general principle is:

Succession is governed by the deceased’s national law.

But the most important exception is:

Immovable property situated in Türkiye is governed by Turkish law.

This means a foreigner’s:

• Turkish apartment;
• villa;
• land;
• commercial property

can be distributed according to Turkish inheritance rules even when other parts of the estate are governed by foreign law.

Where Turkish law applies, descendants are first-ranking legal heirs and children inherit equally.

A surviving spouse inherits:

• one quarter with descendants;
• one half with the deceased’s parent line;
• three quarters with the grandparent line;
• and the entire estate where those heir groups do not exist.

Wills must also be analysed carefully.

A foreign will is not automatically invalid in Türkiye, because MÖHUK recognises testamentary dispositions complying with applicable form rules and the deceased’s national law.

But where the will concerns Turkish real estate, Turkish reserved-share rules may protect:

• descendants;
• parents;
• surviving spouse

against excessive testamentary dispositions.

Foreign heirs usually need to establish their inheritance status before dealing with Turkish assets.

A Turkish inheritance certificate may therefore become essential.

For foreign-element cases, the Civil Court of Peace will often be the appropriate authority, and MÖHUK Article 43 determines jurisdiction by:

• the deceased’s last Turkish domicile;
• or, if none existed, the location of estate assets in Türkiye.

The Court of Cassation reaffirmed this rule as recently as 2 March 2026 in E. 2025/13170, K. 2026/3621.

Foreign probate documents should also be handled carefully.

A certificate obtained abroad should not automatically be assumed sufficient to register Turkish real estate.

TKGM explains that foreign inheritance certificates generally require compliance with the Turkish judicial confirmation framework unless an applicable treaty creates a different route.

Turkish real property can generally pass by inheritance to foreign persons.

However, an important distinction remains:

A person may have the legal capacity to inherit a property but may later be unable to retain it indefinitely under Turkish foreign-property restrictions.

TKGM specifically explains that the inheritance is first transferred and the foreign heir’s ability to retain the real estate is then assessed.

Where statutory nationality or location restrictions exist, the property may have to be disposed of; otherwise liquidation can arise.

Tax should also be addressed immediately.

Türkiye subjects assets located in Türkiye to inheritance and transfer tax regardless of whether the deceased and heirs are foreigners.

For 2026, inheritance tax rates range progressively between 1% and 10%.

The 2026 exemption is:

• TRY 2,907,136 for each qualifying spouse/descendant share;
• TRY 5,817,845 where the surviving spouse is the sole heir.

Even where the estate is below the exemption threshold, an inheritance tax return is generally still required.

The filing deadline depends on:

• where death occurred;
• and where the heirs are located,

and can vary from four to eight months.

The estate’s liabilities are equally important.

Under Turkish law, inheritance can include the deceased’s debts as well as assets.

For this reason, heirs should investigate:

• mortgages;
• bank loans;
• tax debts;
• enforcement proceedings;
• guarantees;
• company liabilities

before treating the estate as financially beneficial.

Where Turkish rejection rules apply, the ordinary period for rejecting inheritance is three months.

A foreign heir who spends several months collecting documents abroad before investigating Turkish debts can therefore face a serious deadline problem.

The safest approach is to deal with the estate in the following order:

First: identify all assets and debts.

Second: determine which country’s law applies to each asset.

Third: identify heirs and obtain inheritance documentation.

Fourth: examine any will.

Fifth: protect rejection-of-inheritance deadlines.

Sixth: complete Turkish inheritance tax formalities.

Seventh: transfer real estate, bank accounts, vehicles and company shares.

Eighth: determine whether foreign heirs may legally retain inherited Turkish property.

The key principle is therefore:

The estate of a foreigner who dies in Türkiye—or owns assets in Türkiye—is not distributed solely according to nationality, place of death or location of heirs. The applicable legal system must be determined separately for each significant part of the estate.

Legal Basis

Law No. 5718 on International Private and Procedural Law

Article 20 — Succession

Article 20 provides that:

• succession is generally governed by the deceased’s national law;
• Turkish law applies to immovable property located in Türkiye;
• rules concerning opening, acquisition and division are governed by the law where estate property is located;
• heirless estates situated in Türkiye pass to the State;
• testamentary form and capacity are governed according to the specific rules in Article 20.

Article 43 — Inheritance Proceedings

Inheritance proceedings are heard:

• at the deceased’s last Turkish domicile;
• or, where no Turkish last domicile exists, where estate assets are located.

Turkish Civil Code No. 4721

Article 495 — Descendants

Children are first-degree statutory heirs and inherit equally.

Predeceased children are represented by their descendants.

Article 499 — Surviving Spouse

The surviving spouse receives:

• 1/4 with descendants;
• 1/2 with the parent line;
• 3/4 with the grandparent line;
• entire inheritance if those groups do not exist.

Article 506 — Reserved Shares

Turkish law protects specified statutory heirs through reserved-share rules, including descendants, parents and the surviving spouse.

Article 598 — Certificate of Inheritance

Legal heirs may obtain an inheritance certificate establishing their status and shares.

Article 599 — Acquisition

Heirs acquire the inheritance as a whole upon death under the Turkish succession framework and can also become responsible for estate debts.

Articles 605–606 — Rejection of Inheritance

Legal and appointed heirs may reject inheritance.

The ordinary period is three months.

Land Registry Rules for Foreign Heirs

TKGM confirms that foreign natural persons can acquire Turkish real estate through inheritance.

Where foreign ownership restrictions prevent the heir from retaining the property, disposal or liquidation may subsequently be required.

2026 Inheritance and Transfer Tax

Türkiye taxes inheritance involving assets situated in Türkiye regardless of nationality.

For 2026:

Inheritance rates: 1%–10%.

Spouse/descendant exemption: TRY 2,907,136 per qualifying heir.

Sole surviving spouse exemption: TRY 5,817,845.

Filing deadlines vary from four to eight months depending on place of death and location of the heirs.

Final Checklist for Foreign Heirs in Türkiye

Before distributing the estate, check:

1. What nationality did the deceased hold?
2. Did the deceased have dual nationality?
3. Where did the deceased die?
4. Where was the deceased’s last domicile?
5. Did the deceased have a Turkish domicile?
6. What Turkish real estate exists?
7. What Turkish bank accounts exist?
8. Are there vehicles?
9. Are there company shares?
10. Are there Turkish debts?
11. Are there assets abroad?
12. Who is the surviving spouse?
13. Who are the descendants?
14. Are there children from earlier marriages?
15. Did any child predecease the deceased?
16. Are parents or siblings relevant?
17. Is there a will?
18. Where was the will executed?
19. What law governed testamentary capacity?
20. Does the will affect Turkish real estate?
21. Are Turkish reserved shares infringed?
22. Is a Turkish inheritance certificate required?
23. Is a foreign inheritance certificate available?
24. Does it require Turkish judicial confirmation?
25. Are apostilles/legalisation required?
26. Are certified Turkish translations complete?
27. Is the three-month rejection period running?
28. Are estate debts greater than assets?
29. Has inheritance tax been calculated?
30. What is the correct declaration deadline?
31. Have the 2026 exemptions been applied?
32. Has the tax return been filed?
33. Has the Turkish real estate been transferred?
34. May the foreign heir legally retain that real estate?
35. Does disposal become necessary?
36. Has the Turkish bank released the account?
37. Have company shares been registered?
38. Have vehicle transfers been completed?
39. Are foreign probate proceedings also required?
40. Is a coordinated multi-country inheritance strategy necessary?

Disclaimer: This article provides general information concerning international inheritance, foreign heirs, Turkish real estate and estate administration in Türkiye as of September 2026. It does not constitute legal advice for a specific estate. International inheritance cases may involve several countries’ laws, bilateral or multilateral treaties, taxation, foreign-property restrictions, debts, wills and procedural deadlines. Each significant estate asset should therefore be analysed separately.