Inheritance with a Foreign Element in Türkiye: Jurisdiction and Law
In inheritances where the deceased or the estate is linked to another country, it matters which country’s court has jurisdiction and which law applies. These questions are determined by the rules of Private International Law.
⚖️ Jurisdiction and Applicable Law
In inheritances with a foreign element, criteria such as Turkish law and Turkish courts for real estate in Türkiye, and the national law of the deceased for movable property, may come into question as a rule. For a foreign court judgment to take effect in Türkiye, recognition and enforcement (tanıma-tenfiz) may be needed. The validity of a willTR made abroad is assessed under the law of the place where it was made and its formal requirements. The process is closely connected with the inheritance rights of foreigners in Türkiye. Legal support matters for the details of each case.
Attention: In inheritances with a foreign element, jurisdiction and applicable law vary according to the distinction between real estate and movables and the national law criteria. For foreign judgments, recognition and enforcement may be needed.
📌 Related Topics
The subject is connected with the inheritance rights of foreigners and the certificate of inheritanceTR.
❓ Frequently Asked Questions
Which law applies in inheritances linked to another country?
Is a foreign court judgment valid in Türkiye?
Is a will made abroad valid?
For detailed information and legal support, you can contact Savun Law & Consultancy.
The information in this article is for general information purposes only and may not be up to date; it may change under current legislation. Each case is unique, and nothing here is a promise of any outcome.
This page is an English adaptation of our Turkish article Yabancılık Unsurlu Miras: Yetki ve Uygulanacak Hukuk.