When a person living or owning assets abroad passes away, one of the most important questions for heirs living in Turkey is , "How do I receive my inheritance from abroad in Turkey?"

The deceased may have a bank account in Germany, real estate in the UK, company shares in the Netherlands, an investment account in Switzerland, or assets in another country. The fact that the heirs reside in Türkiye or are Turkish citizens does not automatically transfer assets held abroad to Türkiye.

To claim an inheritance abroad, it is first necessary to prove heirship, and then complete the inheritance and transfer procedures of the country where the assets are located. After the heir acquires the assets, the transfer of money or other valuables to Türkiye can be carried out separately.

Therefore the process of inheriting property from abroadgenerally consists of three separate stages:

1. Legal determination of heirship,
2. Transfer of assets abroad to the heir's name,
3. Bringing inherited money or assets to Türkiye, or transferring their economic value to Türkiye.

Especially in inheritance cases involving multiple countries, the Turkish Civil Code, Law No. 5718 on International Private Law and Procedural Law, foreign law, and tax legislation should be considered together.

Is it possible to claim inheritance from abroad through Türkiye?

Yes.

A person living in Türkiye can inherit property located in another country. In most cases, it is not a requirement for the heir to live abroad or be a citizen of the country in question.

However, being an heir in Türkiye and actually acquiring assets in a foreign country are two different things.

For example, a person living in Türkiye has a father who lives in Germany:

• bank account,
• car,
• company shares
• immovable property

Even if an heir has obtained a certificate of inheritance from Türkiye, a German bank or land registry office may not be automatically obligated to process the transaction based on this document.

The relevant country's own inheritance laws and procedural rules will also apply.

Therefore, having a certificate of inheritance from Turkey does not automatically mean that the inheritance from abroad will be transferred to Turkey.

Which country's laws apply to inheritance abroad?

In international inheritance disputes, the first step is to determine the applicable law.

According to Article 20 of Law No. 5718 on International Private Law and Procedural Law, the basic rule is as follows:

Inheritance is subject to the national law of the deceased.

However, Turkish law applies to immovable properties located in Türkiye. The Private International Law Act also links certain matters related to the opening, acquisition, and distribution of an inheritance to the law of the country where the estate is located.

Therefore, the nationality of the deceased and the country where the inherited property is located are both of separate importance.

For example, a Turkish citizen might have a bank account in France and a house in Paris. While the deceased's Turkish citizenship is important under Turkish conflict of laws rules, the application of French authorities and French law may be unavoidable in the transfer of real estate in France.

Therefore, in international heritage cases, evaluating the situation solely according to Turkish law is often insufficient.

Can a house or property located abroad be transferred to an heir's name in Türkiye?

The transfer of ownership of real estate located abroad is, as a rule, carried out through the authorities of the country where the property is located.

For example, inherited goods;

• If the house is in Germany, the German authorities,
• If the apartment is in the UK, the British authorities,
• If the property is in France, the French authorities,
• If the real estate is in the US, the relevant state authorities

Action may need to be taken in that regard.

A certificate of inheritance issued by a court or notary in Türkiye does not always guarantee the direct registration of real estate in a foreign land registry in the name of the heir.

The relevant country;

• local inheritance certificate
• Probate decision,
• court order,
• notary document,
• Apostilled Turkish inheritance certificate,
• translation,
• tax certificate

They may request additional documents such as these.

Therefore inherited real estate abroadmust be pursued separately according to the laws of the country where the property is located.

Is it possible to obtain a Certificate of Inheritance from Türkiye?

Yes.

A certificate of inheritance, also known as a probate certificate, is a document that shows whether a person is an heir and what their share of the inheritance will be.

In Türkiye, a certificate of inheritance can be obtained from a civil court or, if the conditions are met, from a notary public, in accordance with Article 598 of the Turkish Civil Code.

However, in cases involving foreign elements;

• the deceased being a foreigner,
• having married in a foreign country
• having a foreign spouse or children,
• Examination of foreign population records,
• the need to apply the laws of another country

Therefore, legal action may be required through the courts.

Whether a certificate of inheritance obtained in Türkiye can be used in a foreign country must be evaluated separately according to the laws of that country.

Is a Turkish Certificate of Inheritance Valid Abroad?

It is not automatically valid in every country.

A certificate of inheritance issued in Turkey a foreign official document .

The relevant foreign country's Turkish inheritance certificate;

• can accept directly,
• may request an apostille
• You can request a sworn translation
• can request an additional decision from its own court
• It may require the completion of a local inheritance or probate procedure.

Therefore, it should not be assumed that money can always be obtained by simply sending a certificate of inheritance obtained from Türkiye directly to a foreign bank.

Does an Apostille automatically make a Certificate of Inheritance valid abroad?

No.

This issue is often misunderstood in practice.

An apostille serves to verify the official status of a document in the country where it was issued. However, an apostille does not automatically guarantee the document's full legal validity in another country.

For example, obtaining an apostille for a certificate of inheritance issued in Türkiye can facilitate the verification of the document's authenticity and official status. However, if the foreign country's law also prescribes a local probate or inheritance procedure, this process must still be carried out.

Therefore:

An apostille is not the same as recognition or legal effect in a foreign country.

Can a certificate of inheritance obtained abroad be used in Türkiye?

A certificate of inheritance or court decision issued in a foreign country may be used in Türkiye.

For example, the heirs of a person who died in Germany may have obtained a certificate of inheritance from the German authorities. However, this document may not be directly sufficient for banking, land registry, or other official transactions in Türkiye.

For foreign court decisions to have the effect of a final judgment or conclusive evidence in Turkey, the recognition provisions in the Private International Law Act are important.

Article 58 of the Turkish Code of Private International Law regulates the recognition of foreign court judgments and states that uncontested judicial decisions can also be considered within this scope. This same regulation is also important for administrative actions taken in Türkiye based on foreign court judgments.

Depending on the nature of the foreign document, a recognition lawsuit or other legal procedure may be required.

What is the difference between recognition and enforcement?

The concepts of recognition and enforcement frequently arise in inheritance proceedings abroad

Recognition allows a foreign court decision to be accepted as a final judgment or conclusive evidence in Türkiye.

Enforcement is necessary for a foreign court decision to be executed in Türkiye.

According to the Turkish Code of Private International Law, the legal effect of foreign court judgments in Türkiye is subject to certain conditions.

It cannot be said that a recognition or enforcement lawsuit must necessarily be filed for every foreign inheritance document. It is necessary to first examine whether the document is a court decision, a notarized document, an administrative document, or a certificate of inheritance.

How to claim inheritance held in a bank account abroad?

One of the most common forms of inheritance abroad is money held in foreign banks.

If the deceased had a bank account in Germany, Switzerland, England, France, the Netherlands, the USA, or another country, the heirs must prove the death and their heirship status to the bank.

In general, the bank;

• death certificate
• inheritance certificate
• heirs' identity cards or passports,
• address documents,
• tax number,
• apostilled documents,
• translations,
• document proving payment of local heritage tax

can request.

However, the required documents vary from bank to bank and from country to country.

In some countries, a probate or similar inheritance procedure must be completed in that country before the bank account can be paid to the heir.

How to bring money from a bank abroad to Türkiye?

Once the inheritance rights have been finalized in a foreign country and the bank is ready to pay the money to the heir, it is possible to send the inheritance share to a bank account in Türkiye.

The transfer is usually done via international bank transfer.

For high-value transfers, the bank in Türkiye;

• the source of the money,
• inheritance certificate,
• foreign bank letter,
• death certificate,
• tax documents

can request.

This is particularly important with regard to bank controls related to preventing money laundering.

Therefore, in high-value inheritance transfers, it is important to keep documentation showing the source of the money.

Is it prohibited to bring inheritance money from abroad to Türkiye?

No.

It is generally possible to transfer money legally inherited to Türkiye.

However, it is important to prepare documents proving the source of the inheritance before any money transfer is made.

Especially for large sums, the bank;

• to which estate the money belongs,
• who the sender is
• the heir's right to ownership,
• whether the necessary tax procedures have been completed in the foreign country

can question.

Therefore, instead of transferring inherited money by dividing it into parts and transferring it from multiple people without explanation, it would be healthier to carry out the transaction with documents that clearly show the inheritance relationship

How to Inherit Shares in a Foreign Company?

If the deceased owned shares in a company located abroad, these company shares may also be included in the estate.

In this situation;

• the laws of the country where the company is established,
• company contract
• Provisions regarding the transfer of shares,
• the deceased's partnership rights,
• company registry

It should be examined.

While some legal systems allow company shares to pass directly to heirs, other types of companies may have special provisions in their articles of association.

Therefore, acquiring shares in a foreign company through inheritance may require a different procedure than collecting a bank account balance.

Can cryptocurrency assets held abroad be inherited?

Since crypto assets also have economic value, they can be inherited.

However, the biggest problem in crypto asset inheritance is often access.

The testator's;

• account on a centralized crypto asset platform,
• cold wallet,
• hardware wallet,
• private keys

It can be found.

It may be possible to apply for an account on a central platform using a death certificate and a certificate of inheritance.

However, the technical inability to access crypto assets in a decentralized wallet whose private keys are unknown can make actual collection impossible, even if an inheritance right exists.

What should be done if there is a will made abroad?

The testator may have prepared their will in a foreign country.

Regarding the validity of a foreign will;

• the form of a will,
• will/testator capacity
• the law of the country in which it was issued,
• the national law of the testator,
• the law of the country where the assets are located

They can be evaluated together.

Article 20 of the Turkish Code of Private International Law also provides special conflict of laws rules with regard to testamentary dispositions.

If a will has been prepared abroad, it is necessary to determine in which country and which legal procedures need to be followed before attempting to enforce the document directly.

Can a lawsuit be filed in Türkiye for inheritance abroad?

Not every dispute can be resolved in Türkiye.

In many cases, changing the title deed of a property located abroad, or paying the balance of a foreign bank account to an heir, requires the authorities of that country to take action.

With this;

• Determination of heir status,
• Recognition of foreign heritage decision,
• Disputes regarding estate assets located in Türkiye,
• Other heritage issues related to Türkiye

It may be possible to apply to Turkish courts in this regard.

In international heritage cases, the country where the case should be filed should be carefully considered before initiating proceedings.

Does the process change if the testator is a Turkish citizen?

Yes, it can vary significantly.

Article 20 of the Turkish Code of Private International Law states that inheritance is, as a rule, subject to the national law of the deceased. Therefore, if the deceased is a Turkish citizen, Turkish inheritance law may apply.

However, the state where the foreign assets are located may reach a different conclusion in accordance with its own rules of private international law.

Particularly with regard to real estate located abroad, the laws of the country where the property is located apply strongly.

Therefore, the idea that "Since the deceased was a Turkish citizen, all transactions can be completed in Türkiye" is not always true.

What should a Turkish heir do if the deceased was a foreigner?

If the person leaving the inheritance is a foreign national, first of all;

1. The nationality of the deceased must be determined
2. A death certificate must be obtained
3. Documents proving the inheritance relationship should be obtained
4. The countries where the assets are located should be identified
5. A specific inheritance procedure should be determined for each country.

For example, if the deceased was a British citizen and the heir was a Turkish citizen, British probate law may need to be applied to obtain access to the bank account in the UK.

In Türkiye, proving heirship alone may not guarantee that a foreign bank will pay the money.

Is there a tax on inheritance abroad in Türkiye?

This issue is particularly important for Turkish citizens.

According to the latest statement from the Revenue Administration, assets acquired by Turkish citizens abroad through inheritance or other gratuitous means are also subject to Inheritance and Transfer Tax under certain conditions.

Therefore, for example, a Turkish citizen could come from Germany;

• €200,000 bank deposit,
• immovable,
• company shares

If the inheritance is received, not only tax obligations in Germany but also inheritance and transfer tax obligations in Türkiye should be assessed.

There are also provisions allowing inheritance taxes paid abroad for the same assets to be taken into account in calculating the tax base in Türkiye under certain conditions.

Therefore, the possibility of double taxation on international heritage assets must be carefully examined.

When should the Inheritance and Transfer Tax Declaration be filed if death occurs abroad?

If the death occurs abroad, the deadline for making the declaration varies depending on the location of the heir.

According to the latest statement from the Revenue Administration, if the death occurred in a foreign country;

• If the heir is in Turkey, 6 months,
• If the heir is located in the country where the death occurred, the deadline is 4 months.
• If the heir is located in another foreign country, 8 months.

A declaration of inheritance and transfer tax must be submitted.

Turkish citizens residing abroad can also submit their declarations through Turkish consulates.

Not missing these deadlines is especially important for high-value foreign heritage assets.

What documents are required for inheritance abroad?

While the required documents vary depending on the country and the nature of the assets, the following are generally requested:

• Death certificate,
• Certificate of inheritance or probate document,
• If there is a will, the original or a certified copy of the will
• The heirs' passports or identity documents,
• Birth certificates,
• Marriage certificates,
• Population records,
• Apostille,
• Sworn translation,
• Documents obtained from foreign tax authorities,
• Bank account information,
• Title deeds or ownership documents,
• Company partnership documents.

The apostille and certification procedure may vary depending on whether the documents will be used in Türkiye or abroad.

Does a death certificate require an apostille?

In most cases, a death certificate obtained from a foreign country needs to be verified for it to be used in Türkiye.

If the country where the document was issued is a party to the Apostille Convention, certification via apostille may be possible.

However, a different procedure may apply if there is a bilateral agreement between Türkiye and the relevant state that eliminates or facilitates document authentication.

Therefore, it should not be assumed that every foreign document automatically requires an apostille; the country of issuance of the document should be checked separately.

Can inheritance abroad be tracked before it arrives in Türkiye?

In most cases, yes.

If the heir is located in Türkiye, the transactions in the foreign country;

• lawyer in a foreign country
• notary,
• bank,
• court,
• tax authority

can be carried out in coordination with.

Similarly, what needs to be done in Türkiye is:

• inheritance certificate
• recognition processes,
• tax return
• Preparation of foreign documents

Such procedures can be handled through a lawyer in Türkiye.

However, according to the laws of a foreign country, there may be proceedings where the heir's personal presence is required.

What happens if one of the heirs abroad does not participate in the proceedings?

When there is more than one heir, it is possible for one heir to live in Türkiye and the others to live abroad.

It is generally not a requirement for all heirs to be in the same country at the same time.

However, the estate;

• sharing,
• sale of real estate,
• distribution of bank accounts,
• transfer of company shares

In proceedings such as these, the participation or representation of all heirs may be required.

If there is a dispute among the heirs, it is also necessary to determine which country's court will resolve the dispute.

How to Investigate the Existence of Inheritance Abroad?

Some heirs are aware that the deceased had assets abroad, but they do not know the full extent of these assets.

For example;

• which bank he/she has an account with
• in which city the property is located,
• where the investment account is kept,
• whether he is a company partner

It may not be known.

There is no single inheritance inquiry system in Türkiye that automatically displays all assets worldwide.

Therefore, in the country where the assets are believed to be located;

• land registry records
• banks,
• company records,
• tax records
• Probate files

Further research may be required.

The deceased's past bank correspondence, tax documents, emails, title deeds, and company papers may also be important in the investigation.

What happens if the inheritance abroad turns out to belong to someone with debts?

Inheritance does not consist solely of assets. The debts of the deceased may also be included in the estate.

Therefore, when investigating assets in the inheritance of individuals who conduct business or have loan debts, especially those operating abroad, it is necessary to also investigate their debts.

The provisions regarding the rejection of inheritance in Turkey may not be the same as the provisions regarding the rejection of inheritance or limited liability systems in foreign countries.

Some countries may prescribe very short time limits for accepting or rejecting an inheritance.

Therefore, if an estate is indebted, the applicable law should be examined before any disposition of assets is made.

How to Bring Inheritance from Abroad to Türkiye?

In practice, the general procedure for bringing inheritance from abroad to Türkiye can be as follows:

1. A death certificate is obtained for the deceased.
2. The heirs and their shares of the inheritance are determined.
3. In Türkiye, a certificate of inheritance is obtained if necessary.
4. The apostille and translation processes required by the foreign country are completed.
5. Local inheritance procedures are followed in the country where the property is located.
6. If necessary, a probate certificate or certificate of inheritance is obtained in a foreign country.
7. Inheritance tax procedures in the foreign country are completed.
8. Bank accounts, real estate, or other assets are transferred to the names of the heirs.
9. If the real estate is to be sold, the sale will be conducted in a foreign country.
10. The inherited money is transferred to Türkiye via bank transfer.
11. Inheritance and transfer tax obligations that may arise in Türkiye are fulfilled.
12. All documents showing the source of the inheritance are kept.

The order and scope of these steps may vary depending on the country where the heritage is located.

Frequently Asked Questions

Can inheritance from abroad be received from Türkiye?

Yes. An heir residing in Türkiye can inherit property in a foreign country. However, the inheritance procedures of the country where the assets are located must also be completed.

Is a certificate of inheritance obtained from Türkiye valid in a foreign country?

It varies from country to country. Some countries accept an apostilled and translated Turkish inheritance certificate, while others may also require a local inheritance or probate process.

Can inheritance money from abroad be sent to Türkiye?

Yes. After the inheritance rights and procedures in the foreign country are completed, the inheritance share can be sent to Türkiye via bank transfer. For high amounts, the bank may request documents showing the source of the funds.

Can I transfer ownership of a house I own abroad to a house in Türkiye?

If the property's ownership is registered in the land registry of the country where it is located, the transfer of ownership must be carried out in that country. A certificate of inheritance obtained in Türkiye can be helpful, but it alone may not change the ownership registered in a foreign land registry.

Do I have to pay tax on inheritance abroad?

Tax liability may arise both in the foreign country where the inheritance is located and, if the conditions are met, in Türkiye. Assets acquired abroad by Turkish citizens through inheritance should be assessed separately for inheritance and transfer tax purposes.

Is a foreign inheritance certificate valid in Türkiye?

Depending on the nature of the foreign court decision or inheritance certificate, recognition or other legal action may be required in Türkiye. The effect of foreign court decisions as final judgments or conclusive evidence in Türkiye is subject to the recognition provisions of the Private International Law Act.

Is obtaining an apostille sufficient?

Not always. An apostille confirms the official nature of a document; it does not replace a court or inheritance procedure if it is required in a foreign country.

Do I need a lawyer for an inheritance abroad?

Attorneys are not mandatory for every inheritance case. However, in cases involving the laws of multiple countries, foreign real estate, bank accounts, company shares, or high-value assets, it is important to plan legal procedures on a country-by-country basis.

Conclusion: Bringing Inheritance from Abroad to Türkiye

It is possible to claim inheritance from abroad in Türkiye; however, the process is not limited to simply obtaining a certificate of inheritance from Türkiye.

First, the status of heir must be determined, and then the necessary procedures must be completed according to the laws of the foreign country where the inheritance is located. In most cases, the transfer of assets such as real estate, bank accounts, and company shares in foreign countries to the heirs is carried out by the competent authorities of that country.

While a certificate of inheritance obtained in Türkiye can be used in transactions in foreign countries, it may not automatically have legal effect in every country. Apostille, translation, foreign court procedures, or probate processes may be required.

After inheritance is legally transferred to the heir in a foreign country, it is possible to transfer the money in the bank account or the proceeds from the sale of real estate to Türkiye. However, especially for high-value transfers, it is important to have documents ready that show the source of the inheritance and the right to inherit.

Furthermore , it is essential to check whether Turkish citizens are liable for inheritance tax in Turkey on inheritances acquired abroad

Therefore, the safest method in inheritance cases abroad is to prepare an inheritance plan on a country-by-country basis by separately determining the citizenship of the deceased, the citizenship of the heirs, the country where the assets are located, and the type of assets.