German families who have accumulated real estate positions in Türkiye over a decade or more increasingly face a different question than the one that brought them into the market. The original question was where to buy. The current question is how to hold what has already been bought, in a way that survives a transfer between generations without triggering forced sales, fragmented ownership, or disputes among heirs.
This shift matters because most German investors entered Turkish property individually, in their own name, often through a single purchase tied to a specific project. That approach works well for one buyer with one objective. It works poorly once children, grandchildren, or multiple branches of a family are involved, because Turkish inheritance law applies forced heirship rules to real estate located in Türkiye regardless of the owner's German nationality or German will. Without a deliberate structure, a portfolio built over twenty years can end up split into awkward fractional shares among heirs who have never met each other and disagree on what to do with the asset.
Why Direct Personal Ownership Breaks Down Over Time
Direct ownership in an individual's name is administratively simple at the point of purchase, but it concentrates every future transaction, whether a sale, a refinancing, or a transfer to the next generation, into a single legal event governed by Turkish succession rules. Each heir becomes a co-owner with veto rights over major decisions under Turkish co-ownership law. Family members living in Germany then find themselves needing Turkish legal representation, notarized powers of attorney, and translated documentation simply to sell an apartment none of them wants to keep.
The Holding Company Alternative
An increasingly common structure among longer-term investors is to consolidate property holdings into a Turkish limited liability company, with the German family holding shares in that entity rather than holding the underlying real estate directly. Shares in a company are more straightforward to transfer, gift, or divide among heirs under both Turkish and German law than fractional ownership of physical property. Decision-making can also be formalized through the company's articles of association, assigning voting rights or management authority in a way that a will alone cannot achieve for real estate.
This approach carries its own costs: corporate tax obligations, annual filing requirements, and the need for a Turkish accountant familiar with real estate holding companies. For a single apartment, the overhead is rarely justified. For a portfolio of several properties or a commercial asset generating rental income, the structure often pays for itself in reduced friction at the point of succession.
Coordinating Turkish and German Estate Rules
Türkiye's forced heirship provisions apply to real property situated in Türkiye even where the owner's habitual residence and overall estate are governed by German law under EU succession principles. Where a holding company owns the property and the German parent owns the company shares, the shares themselves become the asset subject to succession, which gives a German will and German civil law more room to govern the outcome. This is not a way to avoid Turkish forced heirship for the underlying real estate outright, since Turkish courts may still look through the corporate structure in certain disputes, but it materially simplifies the practical transfer and reduces the number of parties who must act jointly for routine decisions.
A Practical Starting Point
Families considering this shift should begin with an inventory: how many properties, in whose name, generating what income, and with what intended recipients. From there, a joint review by a Turkish real estate advisor and a German or cross-border estate lawyer can determine whether consolidation into a single holding vehicle, staged gifting of shares during the current owner's lifetime, or a simpler approach such as usufruct arrangements best fits the family's size and goals. The right structure depends heavily on portfolio size, rental income levels, and how many heirs are expected to remain actively involved in the Turkish assets versus simply receiving proceeds from an eventual sale. Acting before a transfer becomes necessary, rather than after, is what preserves both the value of the portfolio and the relationships among the people inheriting it.