Inheritance in Türkiye – What Applies to You if You Reside in Sweden

Two countries with different points of departure

Sweden applies the EU Succession Regulation and, as a general rule, proceeds from the deceased's place of habitual residence. Türkiye proceeds from nationality and always applies Turkish law to immovable property situated in Türkiye. A person who holds both Swedish and Turkish citizenship is treated in Türkiye as a Turkish citizen.

The consequence may be that the heirs receive shares of different sizes in Sweden and in Türkiye, even though the estate is one and the same.

Where problems most commonly arise

• Surviving spouse and children: In Sweden, the surviving spouse normally inherits everything where the spouses have joint children. Turkish law distributes the estate in an entirely different manner.
• Forced share and will: The rules on forced shares (laglott) in Türkiye differ from the Swedish rules and protect a larger circle of heirs. A will drawn up solely in accordance with Swedish law may be contested in Türkiye.
• Swedish documents are not sufficient: Neither a Swedish estate inventory (bouppteckning) nor a European Certificate of Succession is sufficient to transfer real property in Türkiye. A Turkish certificate of inheritance (veraset ilamı or mirasçılık belgesi), a Turkish inheritance tax return and registration in the land registry (tapu) are required.
• Time limits in both countries: The estate inventory in Sweden and the inheritance tax return in Türkiye must be completed within fixed time limits from the date of death. The time limits run in parallel, and delays may prove costly.
• Outdated information in Turkish registers: A Swedish divorce that has never been registered in Türkiye may result in a former spouse being treated as an heir there.
• Powers of attorney: Heirs in Sweden often grant a power of attorney to someone in Türkiye to handle the matter. A power of attorney drafted too broadly may lead to sales below market value or to an heir renouncing their share without understanding the effect.

Plan in good time

Most of these problems can be prevented. If you own property in Türkiye, your will should be drafted so that it is effective in both countries.

How we can assist you

Sadik Kutlu is a lawyer qualified in both Sweden and Türkiye and works in Swedish, Turkish and English. We handle the entire matter in a coordinated manner, including both the estate inventory and the distribution of the estate (arvskifte) in Sweden, and the certificate of inheritance, inheritance tax and land registration in Türkiye, so that the outcome is the same in both countries. As a rule, the heirs do not need to travel to Türkiye.

Every inheritance matter with a connection to Türkiye is different. Please contact us for an initial assessment of your particular situation.