Uzbek investors who acquire residential or commercial property in Türkiye rarely think about succession planning at the point of purchase. Yet when an owner passes away without a clear plan, heirs in Tashkent or Samarkand can face a probate process governed by Turkish law, not Uzbek law, and the two systems do not always align. Understanding how cross-border estate matters are handled before a transaction closes, rather than after a death in the family, saves heirs significant time, cost, and uncertainty.
Which Law Applies to a Turkish Property
Türkiye applies the principle of lex rei sitae for immovable property: real estate located in Türkiye is generally distributed according to Turkish inheritance law, regardless of the deceased's nationality or the terms of a will drafted in Uzbekistan. This means a will executed in Uzbekistan that conflicts with Turkish forced-heirship rules may only be partially enforceable with respect to the Turkish property, even if it is fully valid for assets located in Uzbekistan. Movable assets, such as funds in a Turkish bank account, can be treated differently depending on the applicable conflict-of-laws analysis, so each asset class in an estate needs to be reviewed separately.
Turkish law reserves a mandatory share of an estate, known as the saklı pay, for close relatives such as children, a surviving spouse, and in some cases parents. A foreign will that attempts to override these reserved shares for Turkish real estate can be challenged by the protected heirs in a Turkish court, which is why estate plans drafted purely under Uzbek law often need a parallel review under Turkish rules.
The Probate Process Itself
When an Uzbek property owner passes away, heirs typically need a certificate of inheritance, called a veraset ilamı, issued either by a Turkish notary or a Turkish civil court. For foreign nationals, notaries frequently decline to issue the certificate directly and refer the matter to court, which lengthens the timeline. The court will usually require an official document from Uzbekistan confirming the legal heirs, translated into Turkish and apostilled or otherwise legalized, along with certified translations of the death certificate and any will.
Once the certificate of inheritance is obtained, heirs must complete an inheritance tax declaration with the Turkish tax authority within the statutory period, even if the eventual tax liability is minimal. Only after the tax filing is acknowledged can the title transfer at the Land Registry Directorate proceed. Heirs who are not physically present in Türkiye typically appoint a Turkish lawyer or a trusted representative under a notarized power of attorney to handle filings, which should ideally be arranged well before it is needed, since obtaining a fresh power of attorney from abroad after a death adds further delay.
Practical Steps for Current Owners
Uzbek investors holding Turkish property should keep a clear, updated file of ownership documents, tax numbers, and property deeds accessible to a designated representative in Türkiye. Where the estate includes multiple heirs across two countries, a Turkish-law-compliant will, drafted in coordination with a local notary and reviewed against Uzbek succession documents, reduces the likelihood of disputes over the reserved share rules. Property held through a Turkish company structure, rather than in an individual's name, follows a different succession path involving corporate shares rather than direct real estate transfer, which some families find easier to administer across borders, though it introduces its own tax and governance considerations.
It is also worth noting that residency or investment status obtained through property ownership, including any route connected to Türkiye's citizenship-by-investment threshold, does not itself resolve inheritance questions. The property remains subject to Turkish succession rules independent of how it was acquired.
Planning Ahead
Cross-border succession is one of the more overlooked aspects of property ownership abroad. For Uzbek families building a real estate footprint in Türkiye, early coordination between legal advisors in both jurisdictions, together with properly authenticated documentation, is the most reliable way to ensure that a Turkish property passes to the intended heirs without unnecessary delay or dispute.