For Uzbekistan nationals who have acquired residential or commercial property in Türkiye over the past decade, the conversation eventually shifts from acquisition to legacy. Türkiye's inheritance framework differs meaningfully from Uzbekistan's, and investors who plan ahead avoid disputes, delays, and unnecessary tax exposure for their heirs.
Türkiye's Forced Heirship System
Türkiye applies a civil law inheritance regime rooted in forced heirship (saklı pay), meaning a fixed share of an estate is reserved by law for spouses, children, and in some cases parents, regardless of what a will states. This differs from common law jurisdictions where a testator has near-total freedom to distribute assets. For Uzbekistan investors accustomed to a different domestic framework, this distinction matters most when a Turkish property is meant to pass to a business partner, a specific child, or an entity rather than being split according to statutory shares.
Under Turkish private international law, movable assets are generally governed by the deceased's national law, while real estate located in Türkiye is typically subject to Turkish law regardless of the owner's nationality. This means a Turkish apartment or commercial unit will, in most cases, be distributed according to Turkish inheritance rules even if the owner's will was drafted under Uzbek law.
Practical Structuring Options
Investors have several tools available. A Turkish-law-compliant will (vasiyetname), drafted and notarized in Türkiye, ensures clarity for local authorities and reduces the risk of conflicting instruments across jurisdictions. Holding property through a Turkish legal entity, such as a limited liability company, is another common approach: shares in the company, rather than the real estate itself, become the inherited asset, which can simplify transfer mechanics and, depending on structure, offer more flexibility than direct real estate ownership.
Joint ownership structures and usufruct arrangements (intifa hakkı) are also used by families who want to transfer eventual ownership to children while retaining lifetime use and income rights. These structures require careful drafting to avoid unintended tax triggers or disputes among heirs.
Tax Considerations
Turkish levies inheritance and gift tax (veraset ve intikal vergisi) on transfers of Turkish-located assets, with progressive rates depending on the value transferred and the relationship between the deceased and the heir. Foreign heirs are generally subject to the same regime as Turkish nationals for property located in Türkiye. Investors should also confirm whether Uzbekistan applies any parallel tax treatment on foreign-held assets, since double taxation exposure, while limited in this area, is worth reviewing with a cross-border tax advisor before finalizing a structure.
Documentation and Registration
Heirs inheriting Turkish property typically need a certificate of inheritance (veraset ilamı), obtainable either through a Turkish civil court or a notary, before the Land Registry will process a transfer. For foreign nationals, this process can be slower if underlying documents such as marriage certificates, birth certificates, or prior wills were issued in Uzbekistan and require apostille or consular legalization plus certified Turkish translation. Investors who prepare these documents in advance, rather than leaving heirs to assemble them after a death, materially shorten the settlement timeline.
Coordinating Two Legal Systems
The most common mistake among foreign property owners is treating a will drafted at home as automatically valid for Turkish assets. While Türkiye recognizes foreign wills in principle, applying one to real estate located within the country often requires additional local formalities, and conflicts between a home-country will and Turkish forced heirship rules can create years of litigation for heirs. A coordinated approach, ideally involving both an Uzbek and a Turkish legal advisor, is the more reliable path.
Recommendation : Investors with meaningful Turkish real estate holdings should review their ownership structure and succession documents every few years, particularly after major life events such as marriage, the birth of a child, or a significant change in portfolio value. Early planning costs little relative to the complexity it prevents for the next generation.