Finnish citizens who purchase real estate in Türkiye rarely think about what happens to that property when they pass away. Yet cross-border succession is one of the more procedurally complex issues a foreign owner can leave behind for their heirs, and Finland's inheritance framework interacts with Türkiye's in ways that surprise families who assumed one jurisdiction's will would simply carry over.
Two Legal Systems, One Property
Türkiye applies the principle of lex rei sitae for immovable property: real estate located in Türkiye is governed by Turkish inheritance law, regardless of the deceased's nationality or place of residence. This holds even if the deceased held a valid Finnish will drafted under Finland's Perintökaari (Inheritance Code) and even if that will was properly probated in Helsinki.
In practice, this means a Finnish will covering a Turkish apartment or villa may need to be recognized separately through Turkish probate procedure before title can transfer to heirs. The Finnish probate certificate is a useful starting document, but it is not automatically enforceable against the Turkish land registry.
Reserved Shares : Turkish inheritance law includes mandatory reserved shares (saklı pay) for close relatives, spouse, and children, which can override the distribution stated in a foreign will for property located in Türkiye. Finnish forced-heirship rules differ in structure, so heirs and estate planners should confirm how the Turkish reserved-share regime will apply to a specific portfolio before assuming the will's instructions control outcomes.
The Probate Sequence in Türkiye
For a Finnish estate with Turkish real estate, the typical sequence involves obtaining a certificate of inheritance (veraset ilamı) from a Turkish civil court of peace, or in some cases a notary, based on the foreign death certificate and proof of heirship. Turkish courts generally require an apostilled and translated Finnish death certificate and, where relevant, a translated and apostilled copy of the Finnish probate decision.
Where heirs are not resident in Türkiye, a locally appointed and Turkish-registered power of attorney is typically used to handle the certificate application, land registry transfer, and any tax filings, since most of this process cannot be completed remotely without one.
Inheritance Tax : Turkish levies inheritance and transfer tax on real estate passing to heirs, calculated on a progressive scale and payable over several years in installments. This is separate from, and not offset against, any Finnish inheritance tax paid domestically, since Türkiye and Finland do not have a bilateral estate or inheritance tax treaty. Heirs should budget for potential exposure in both jurisdictions and consult tax advisors in each country rather than assuming a credit will apply automatically.
Practical Steps Before It Becomes a Problem
Finnish owners of Turkish property are generally better served by addressing succession planning at the time of purchase rather than leaving it to heirs to untangle later. A few measures reduce friction meaningfully.
Drafting a Türkiye-specific will, notarized in Türkiye and covering only the Turkish assets, is a common approach among foreign owners with cross-border estates. This does not need to conflict with a Finnish will covering worldwide assets, provided the two documents are drafted with awareness of each other and reference Turkish reserved-share rules explicitly.
Maintaining updated, apostilled copies of civil status documents, and confirming that property title records reflect the correct legal owner (particularly where property was purchased through a company structure or joint ownership arrangement), also shortens the probate timeline considerably.
Company or Trust Holding Structures : Some Finnish investors hold Turkish property through a Turkish or third-country corporate entity rather than personal name, partly to simplify succession. This can work, but it introduces its own compliance obligations, including Turkish corporate filings and beneficial ownership disclosure, and should be evaluated against the property's scale and intended holding period rather than adopted by default.
Why This Matters for Buyers Now
None of this needs to be resolved on the day of purchase, but it is far easier to plan a title structure, a will, and a power of attorney arrangement in advance than to reconstruct heirship years later through two court systems simultaneously. Advisors working with Finnish clients on Turkish acquisitions should treat succession planning as a standard part of the closing checklist, not an afterthought raised only when a client asks.
Eurasia Experts works with Finnish investors and their legal counsel to coordinate property acquisitions, title verification, and succession-related documentation in Türkiye, connecting clients with qualified local notaries and legal advisors as needed.