Pakistani families who have acquired an apartment in Istanbul, a villa on the Aegean coast, or a commercial unit in a growth corridor rarely ask what happens to that asset if the owner passes away while still holding both Pakistani and Türkiye-based property. It is a reasonable question to defer during the excitement of a purchase, but it becomes urgent, and considerably harder to resolve, once it is no longer hypothetical. Türkiye applies its own succession law to immovable property located within its borders, largely independent of what a Pakistani will or a Pakistani court has already decided.
Why Türkiye Applies Its Own Rules to Real Estate
Under Turkish private international law, movable assets such as bank accounts are generally governed by the law of the deceased's nationality, but immovable property, meaning land and buildings, is governed by Turkish law regardless of where the owner was domiciled or which country's courts issued a prior ruling. This is the lex situs principle, and it means a Pakistani succession certificate or a will probated in Lahore or Karachi does not automatically transfer title to a Turkish property. The heirs still need a process inside the Turkish system before the Land Registry (Tapu ve Kadastro) will update ownership records.
Practical effect : even a clean, uncontested Pakistani probate does not skip the Turkish step. It supports the Turkish process as evidence, but it does not replace it.
The Veraset İlamı: Türkiye's Certificate of Inheritance
The starting point for heirs is obtaining a veraset ilamı, an inheritance certificate issued either by a Turkish civil court of peace (Sulh Hukuk Mahkemesi) or, in straightforward cases involving Turkish citizens, by a notary. For foreign nationals, including Pakistani citizens, the certificate is typically obtained through the court, which will want documentation establishing the identity of the deceased, the identity and relationship of the heirs, and confirmation that no other claimants exist. A Pakistani succession certificate, death certificate, and family registration documents, properly apostilled or legalized and translated into Turkish by a sworn translator, form the evidentiary backbone of this application.
Because Pakistan and Türkiye handle apostille and document legalization differently depending on the issuing authority, heirs should confirm early whether Pakistani-issued documents require attestation through Türkiye's consular channels or qualify under the Hague Apostille Convention, and build extra time into the process for this step alone.
Tax Clearance Before Transfer
Turkish inheritance and gift tax (Veraset ve İntikal Vergisi) applies to property located in Türkiye even when the heirs are non-resident foreign nationals. Rates are progressive and calculated on the declared value of the inherited asset, with a filing obligation that generally falls within four months of the death if the deceased passed away in Türkiye, or six to eight months if abroad, depending on residence. A tax clearance certificate from the relevant Turkish tax office is a prerequisite for the Land Registry to process the transfer, so this cannot be skipped or handled informally.
Multiple Heirs and Fragmented Ownership
Under Turkish succession rules, property typically passes to heirs in shared, undivided ownership (elbirliği or paylı mülkiyet) rather than to a single designated recipient, unless a will specifies otherwise and that will has been recognized through the Turkish court process. For families with several heirs across Pakistan and elsewhere, this often means the property sits in joint name until the heirs agree to partition it, sell it, or have one heir buy out the others. Disagreements at this stage are common and can stall a sale for years, particularly when heirs are not all resident in the same country and communication or trust between branches of the family has weakened.
Reducing the Burden in Advance
A properly drafted Turkish will, executed before a Turkish notary and registered with the central will registry, can simplify this considerably by specifying Turkish law as governing the Turkish estate and naming clear beneficiaries, reducing reliance on cross-border document chains at the time of death. Powers of attorney granted to a trusted local representative, kept current and specific, also materially shorten the timeline when heirs cannot travel to Türkiye quickly.
Eurasia Experts advises Pakistani property owners in Türkiye to treat succession planning as part of the acquisition process itself, not an afterthought, and to coordinate a Turkish notary, a sworn translator, and local legal counsel before a transfer becomes urgent rather than after.