Recognising a Foreign Inheritance or Succession Ruling in Türkiye

You hold a court ruling from abroad that settles who inherits — and part of the estate sits in Türkiye (Turkey). On its own, that ruling usually does not count here: a Turkish court must first recognise it (recognition, or tanımaTanımaRecognition of a foreign judgment in TürkiyeThe court decision that makes a foreign judgment legally effective in Türkiye as proof — without, by itself, making it enforceable.Glossary → ) before it carries weight, and for Turkish real estate a separate Turkish route almost always applies. This guide explains how recognition and, where something must actually be carried out, enforcement work for succession decisions. It also covers the one limit that surprises most families: a foreign court generally cannot decide who owns property located in Türkiye. Read on to see which route fits your situation, and how movable and immovable assets are treated differently.

Does a foreign inheritance ruling automatically count in Türkiye?

No. A judgment from a foreign court has no automatic force in Türkiye. Before it can be relied on, you generally need a Turkish court to recognise it — recognition (tanıma) — or, where the ruling orders something to be carried out, to enforce it — enforcement (tenfizTenfizEnforcement of a foreign judgment in TürkiyeThe Turkish court decision that makes a foreign judgment enforceable in Türkiye — the step that lets you actually collect.Glossary →).

The two are related but not the same. Recognition treats the foreign judgment as a settled matter here (it has res judicata and evidentiary effect — the question is closed and the judgment can be used as proof). Enforcement goes one step further: it makes the judgment executable in Türkiye, so it can be acted on like a Turkish judgment.

For most inheritance cases, the first thing you need is recognition — a point we unpack next. To see how the two ideas differ in practice, read our guide on recognition versus enforcement (tanıma vs tenfiz), or the overview on our recognition and enforcement of foreign judgments service.

Recognition (tanıma) or enforcement (tenfiz) — which does a succession ruling need?

Most succession rulings need recognition (tanıma), not enforcement. That is because a typical inheritance judgment simply establishes a status — who the heirs are, what their shares are, or whether a will is valid. Nothing has to be physically "carried out"; the ruling just needs to be treated as settled in Türkiye. Recognition does exactly that.

You reach for enforcement (tenfiz) only when the foreign judgment orders something to be performed — for example, a money payment out of the estate, or an order that a specific person hand over an asset. An order like that has to be made executable before Turkish enforcement offices can act on it.

The practical takeaway: because recognition does not require reciprocity, a status-type inheritance ruling can often be recognised even where a money judgment from the same country would face the extra reciprocity hurdle.

Can a foreign court decide who owns real estate in Türkiye?

Generally, no. This is the single most important limit to understand. Rights over immovable property — land, an apartment, a house — located in Türkiye fall within the exclusive jurisdiction of the Turkish courts. "Exclusive jurisdiction" means only a Turkish court may decide the matter; no foreign court can. On top of that, allowing a foreign court to decide title to Turkish real estate is treated as contrary to Turkish public policy (kamu düzeni — the country's core legal order).

MÖHUKMÖHUKTurkish Private International Law Act No. 5718The Turkish statute that decides which country's law applies to a cross-border matter, and how foreign judgments are recognised and enforced here.Glossary →'s conditions reflect both concerns. A foreign judgment cannot be recognised or enforced if it is on a matter within the exclusive jurisdiction of the Turkish courts, or if it is manifestly contrary to public policy (Art. 54). Under settled Turkish practice, a foreign ruling that purports to award, transfer, or decide title to Turkish real estate runs into both of these and generally cannot be given effect here for that purpose.

For a fuller look at how the public-policy filter is applied, see our guide on public policy (kamu düzeni) and refusal, and our inheritance and succession service for the Turkish-side process.

How are Turkish assets actually transferred — the certificate of inheritance (veraset ilamı) route?

Through Turkish succession procedure, using a Turkish certificate of inheritance. For assets located in Türkiye — especially immovable property — heirs normally obtain a certificate of inheritance (veraset ilamı): an official Turkish document that names the heirs and sets out their shares.

With that certificate, and after the inheritance-tax steps are completed, the Turkish institutions can act:

• The Land Registry (Tapu) can update the title records for immovable property in Türkiye;
• Banks can release accounts and other holdings to the recognised heirs;
• Company shares and other registered assets can be transferred to the heirs.

A foreign will or a foreign heirship ruling is not useless here — it can support the application and help prove the family and testamentary picture. But it is the Turkish document that the Land Registry and banks actually act on.

Movable vs immovable, status vs asset-transfer — why does the line matter?

Two distinctions decide your route. The first is movable versus immovable property. The second is establishing status (who the heirs are) versus transferring an asset (putting a specific thing into someone's name). The immovable + asset-transfer combination is where a foreign ruling hits the hard limit; the other combinations are more flexible.

In short: recognising who the heirs are is one question; moving a Turkish apartment into their names is a different one — and the second is a Turkish matter, whatever a foreign court has said.

What conditions must the foreign judgment meet, and in which court?

Answer: the foreign judgment has to clear a defined set of conditions, and the case is heard by a specific Turkish court. The Turkish court checks these conditions — it does not re-run the case.

The core conditions under MÖHUK Article 54 (which also apply to recognition under Article 58, minus reciprocity) are:

• Final and binding. The judgment must be final in its home country (kesinleşmiş) — Art. 50.
• Reciprocity between Türkiye and the country of origin, by treaty, statute, or actual practice — required for enforcement (Art. 54), but not for recognition (Art. 58).
• Not within Turkish exclusive jurisdiction — Art. 54. This is the condition that blocks a foreign ruling over Turkish real estate.
• Not manifestly contrary to Turkish public policy (kamu düzeni) — Art. 54.
• The defendant's right to a proper defence was respected — proper notice and service — Art. 54.

For the conditions in more depth, see our guide on the documents a tenfiz case needs, which also covers how these requirements are proven on paper.

What documents and steps does a recognition or enforcement case need?

Answer: a properly finalised and translated foreign judgment, a power of attorney, and — for some claimants — security for costs. The paperwork does most of the work, and you usually do not have to be in Türkiye for any of it.

1. A final judgment. The foreign judgment must be final, ideally with a finality annotation (kesinleşme şerhi) from the court that issued it.
2. Apostille or consular legalisation. The judgment is authenticated with an apostille under the 1961 Hague Apostille Convention, or, where that convention does not apply, through consular legalisation.
3. Sworn Turkish translation. The judgment and its annotations are translated into Turkish by a sworn translator.
4. Power of attorney (vekâletname). This lets a lawyer admitted to a Turkish bar run the entire case for you — you do not need to travel.
5. Security for costs, if it applies. A foreign claimant may have to post security for costs (yabancılık teminatı) under the Code of Civil Procedure (HMK, Art. 84), unless a treaty or reciprocity exemption removes the requirement.

After a favourable enforcement (tenfiz) judgment, the decision is carried out against assets in Türkiye through the enforcement offices under the Enforcement and Bankruptcy Act (İİKİİKEnforcement and Bankruptcy Law No. 2004The Turkish statute governing how debts are collected by force — enforcement proceedings, attachment, sale and bankruptcy.Glossary →, Law No. 2004).

What if a foreign divorce changes who inherits?

Answer: a foreign divorce that affects inheritance rights — for example, a former spouse who should no longer inherit — must first be recognised in Türkiye before it changes anything here. Until then, the Turkish records may still treat the marriage as intact.

There are two routes to give a foreign divorce effect in Türkiye:

• Recognition (tanıma) before a Turkish family court under MÖHUK Article 58; or
• Administrative registration — since 2017, a foreign divorce can be registered directly in the Turkish population register through the civil registry or a consulate under the Population Services Act (Law No. 5490, Art. 27/A), when the conditions are met, without a court case.

Which route fits depends on your circumstances. This is a specialist area in its own right — our divorce and family law service covers the detail, so here we only flag the link to succession: sort out the divorce recognition, and the heirship picture follows.

What's the practical path forward?

Winning abroad is real progress — but making it "count" in Türkiye is a separate, structured step. The path usually looks like this: identify whether you need recognition or enforcement; separate the movable estate from any Turkish real estate; recognise the foreign ruling for status and cross-border effect; and handle the Turkish assets through Turkish succession procedure and a certificate of inheritance.

The earlier the two tracks are lined up, the fewer surprises later — especially around the immovable-property limit, which catches families who assumed a foreign judgment would simply move a Turkish apartment into their names.

If you are holding a foreign inheritance judgment, a will, or a divorce decree that touches an estate in Türkiye, you can set out your situation through our start here page, and a lawyer can advise on the route that fits. A power of attorney means the whole matter can usually be run without you travelling.

This article is general information about Turkish law and is not legal advice; for advice on your specific situation, consult a qualified lawyer.

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