Enforcing Foreign Inheritance Decisions in Türkiye
When a deceased person has assets abroad or the estate is opened in a foreign country, the rules of private international law come into play. In inheritance disputes with a foreign element, it matters which country's law applies and how foreign decisions take effect in Türkiye.
⚖️ How Do Foreign Inheritance Decisions Take Effect in Türkiye?
Under the Turkish Act on Private International Law and Procedure (MÖHUK), inheritance is as a general rule governed by the national law of the deceased; however, Turkish law applies to immovable property located in Türkiye. For an inheritance decision obtained from a foreign court to be enforced in Türkiye, a recognition or enforcement (tenfiz) action may need to be filed. In these cases, conditions such as the foreign decision being final and not contrary to public order are required.
In short: In inheritances with a foreign element, the applicable law is determined under MÖHUK; Turkish law applies to immovable property in Türkiye, and recognition or enforcement may be needed for foreign decisions.
📌 Related Topics
This topic is related to international inheritance and jurisdiction and the inheritance rights of foreigners in Türkiye.
❓ Frequently Asked Questions
Is an inheritance decision from a foreign country valid in Türkiye?
Which country's law applies to immovable property in Türkiye?
Which country's law applies to an inheritance?
For detailed information and legal support, you can contact Savun Law & Consultancy.
For information on estates abroad and enforcement, you can contact Savun Law & Consultancy.
The information in this article is for general information only and may not be up to date as legislation changes. Every case is different and nothing here promises a result. Savun Law & Consultancy cannot be held responsible for decisions taken solely on the basis of this article.
Questions & answers · Istanbul Bar Association 75235
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Have a question? Attorney Veli Savun answersThis page is an English adaptation of our Turkish article Yurt Dışında Bırakılan Terekenin Türkiye'de Tenfizi.