Saudi investors who acquire residential or commercial property in Türkiye often focus on yield, location, and entry price. Fewer stop to ask what happens to that property if the owner passes away while the asset is still held under Turkish title. Inheritance in Türkiye follows Turkish civil law for real estate located within its borders, regardless of the owner's nationality or the succession rules that would otherwise apply under Saudi practice. This distinction matters more than most buyers realize, and it is worth addressing before a transaction closes, not after a family emergency forces the issue.
Why Turkish Law Governs, Not Saudi Law
Türkiye applies the principle of lex rei sitae for immovable property: the law of the country where the asset is located determines how it is inherited. This means a villa in Bodrum or an apartment in Istanbul passes according to the Turkish Civil Code's forced heirship rules, even if the owner's will was drafted in Riyadh under Saudi Sharia-based succession principles. Saudi nationals accustomed to fixed hereditary shares should understand that Turkish forced heirship allocates fixed reserved portions to a surviving spouse and children, and the two systems do not map onto each other automatically. Without planning, a family can end up with an unintended split of ownership among heirs who may not agree on whether to sell, rent, or retain the asset.
Key point : A will executed in Saudi Arabia is not invalid in Türkiye, but it cannot override the reserved shares that Turkish law guarantees to close relatives. Testamentary freedom exists only over the portion of the estate beyond those reserved shares.
Practical Structuring Options
Investors typically choose among a few approaches. Direct personal ownership is the simplest at acquisition but produces the most complex succession outcome, since title passes directly into a shared inheritance regime among multiple heirs, each becoming a co-owner. Holding the property through a Turkish company structure, by contrast, converts the asset into shares of a legal entity. Shares are more straightforward to transfer, gift, or allocate among family members during the owner's lifetime, and succession of company shares can sometimes be planned with more flexibility than succession of the underlying real estate itself. This route adds setup and maintenance costs, so it tends to suit larger portfolios rather than a single holiday apartment.
A Turkish notarized will, drafted with the reserved-share rules in mind, is another practical layer. It does not replace a Saudi will covering worldwide assets, but it gives Turkish courts and land registries (Tapu) a clear, locally enforceable instruction for the Turkish-situated property specifically, reducing the chance of delay or dispute during probate.
The Probate Process in Practice
When an owner passes away, heirs must obtain a certificate of inheritance (veraset belgesi), either from a Turkish notary or through the courts, before the Tapu registry will transfer title. For foreign nationals, this process typically requires apostilled documentation from the home jurisdiction confirming the identity of heirs and their entitlement shares, translated and notarized in Türkiye. Delays are common when family documentation was never prepared in advance, and in cross-border estates the process can extend well beyond what heirs expect, particularly if any heir resides outside Türkiye and cannot appear in person without a power of attorney.
Practical note : Appointing a Turkish power of attorney holder, ideally a trusted advisor or legal representative, before any succession event occurs can shorten this process considerably and avoid the need for heirs to travel during an already difficult period.
What This Means for Ongoing Ownership Decisions
Succession planning also intersects with everyday portfolio decisions. Property held jointly with a spouse, gifted early to adult children, or restructured into a holding entity each carries different implications for how the estate eventually divides. Investors building a multi-property Turkish portfolio, whether for rental income or long-term family use, benefit from reviewing ownership structure periodically rather than treating the initial purchase decision as final.
Eurasia Experts advises Saudi clients on structuring Turkish real estate holdings with succession outcomes in mind from the outset, coordinating with local notaries and legal counsel so that ownership documentation, wills, and eventual title transfer align with both family intentions and Turkish civil law requirements.