Turkish Inheritance Certificate: Is It Recognized in Germany — and Does a German Erbschein Work in Turkey?

You finally have your Turkish inheritance certificate — the mirasçılık belgesi, also called veraset ilamı — in hand. You walk into a German bank branch or the local Grundbuchamt (land registry) expecting the matter to be settled, and you're told: "this document alone isn't enough." Or the reverse happens: you hold a German Erbschein and try to transfer a family property in Bodrum into your name, and the Turkish land registry refuses the document outright. Both scenarios are common, and both are avoidable if you understand, before you start, which document actually works where.

Our guide to obtaining the Turkish inheritance certificate explains how to get the document in the first place. This piece picks up where that one leaves off: what actually happens once you hold either document and need to use it in the *other* country.

1. The Core Rule That Surprises Most Heirs

A Turkish inheritance certificate is not automatically valid in Germany, and a German Erbschein is not automatically valid in Turkey. There is no automatic mutual recognition system between the two countries for inheritance certificates as such. Whether a document actually works in practice depends on three things:

2. Which Law Governs at All: The 1929 Treaty, MÖHUK, and Why the EU Succession Regulation Doesn't Apply

The 1929 Nachlassabkommen (Estates Agreement)

Germany and Turkey are still governed today by the Annex to Article 20 of the German-Turkish Consular Convention of 28 May 1929 — commonly called the Nachlassabkommen. It regulates, among other things, which consulates and authorities have jurisdiction over succession matters involving the other country, and how estate assets in the other state are handled. As a bilateral treaty with a third country, this agreement takes precedence over the EU Succession Regulation for German-Turkish cases.

Why the EU Succession Regulation (No. 650/2012) Doesn't Reach Turkey

The EU Succession Regulation (No. 650/2012), and the European Certificate of Succession (ECS) built on it, applies only between participating EU Member States (Ireland and Denmark opted out; the UK was never bound). Turkey is not an EU Member State, so the Regulation has no direct effect on purely Turkish estate assets or before Turkish authorities. An ECS is worthless for an apartment in Ankara.

The ECS does become relevant in one specific scenario: if the deceased's last habitual residence was in an EU Member State (e.g. Germany) and the estate also includes assets in another EU country, an ECS can be issued for that EU-internal portion, running in parallel to the Turkish inheritance certificate covering the Turkish portion. In that case, the ECS does not replace the Turkish certificate — it only covers the intra-European slice of the estate.

MÖHUK: Which Law Decides Who Inherits?

For the underlying question of which substantive succession law even applies, the relevant framework from a Turkish standpoint is Turkey's own private international law statute — MÖHUK (Law No. 5718 on Private International and Procedural Law). The basic rule:

This split — known as scission of succession (Nachlassspaltung) — is why one and the same death can be treated under two different legal regimes in the two countries, even where the same people end up as heirs on both sides.

3. Comparison Table: Turkish Inheritance Certificate vs. German Erbschein vs. European Certificate of Succession — Who Accepts What?

⚠️ Important: This table has one takeaway many heirs underestimate: there is no way around a Turkish inheritance certificate for Turkish real estate — no German Erbschein and no ECS, however carefully apostilled and translated, substitutes for it at the Turkish land registry.

4. Using a Turkish Inheritance Certificate in Germany: Banks and the Grundbuchamt

At German banks

For a German bank account belonging to a deceased Turkish national, banks in practice generally accept the Turkish inheritance certificate — provided it comes apostilled and with a certified German translation. Banks apply their own internal compliance standards, so the exact level of scrutiny varies by institution, and sometimes by branch. Common additional requirements:

At the German Grundbuchamt (land registry)

For German real estate belonging to a Turkish deceased, the Grundbuchamt typically requires proof of heirship in a form that meets German procedural standards. A merely apostilled Turkish inheritance certificate is not treated uniformly as sufficient by every land registry office — this is where the Fremdrechtserbschein under § 2369 BGB, already described in our inheritance certificate guide, comes in: the German probate court, on application, issues an Erbschein under Turkish law that carries the form the German land registry requires.

Practical note: Whether a Fremdrechtserbschein is strictly required in a given case, or whether the Grundbuchamt will accept the foreign certificate with supplementary evidence, is decided at the discretion of the competent German court — this is a question of German procedural law, and we refer you to a German lawyer specializing in inheritance law or a notary.

5. Using a German Erbschein in Turkey: Land Registry and Banks

For real estate: practically impossible without a Turkish certificate

The Turkish land registry (Tapu Müdürlüğü) strictly applies the location principle for real estate and accepts only a Turkish inheritance certificate for a property transfer — either one obtained directly in Turkey, or a foreign document formally approved by a Turkish court as consistent with Turkish succession procedure. A German Erbschein on its own, even apostilled and certified-translated, is not sufficient for this purpose.

For bank accounts and movable assets: somewhat more flexibility, but rarely automatic

For purely movable assets (bank balances, vehicles) in Turkey, MÖHUK Art. 20 generally applies the deceased's national law — for a German deceased, that means German succession law applies substantively. That does not mean a Turkish bank will automatically accept a German Erbschein at face value. In practice, Turkish banks typically require either

A merely apostilled German Erbschein, without a Turkish court's formal confirmation, is generally not treated as sufficient by Turkish banks — particularly for larger sums or where the heirs are not undisputedly established.

6. Apostille and Certified Translation: The Minimum Formal Requirements for Cross-Recognition

7. A Practical Dual-Track Strategy for Heirs with Assets on Both Sides

1. Map the estate first. Before applying for any document, work out exactly what sits where — real estate, accounts, vehicles — and in which country. That determines which document you actually need.

2. Apply for both certificates in parallel, not one after the other. Heirs who wait for the German Erbschein before starting the Turkish process lose valuable time — especially given Turkish inheritance tax filing deadlines (4–8 months). With the right powers of attorney, both procedures can run simultaneously.

3. Consider the Fremdrechtserbschein proactively whenever a Turkish deceased leaves German movable or immovable assets and a German Grundbuchamt is involved — raise this with a German notary or specialist lawyer early.

4. For Turkish real estate, plan for a Turkish inheritance certificate from day one, even if all you hold at first is a German Erbschein. Neither an ECS nor an apostilled German Erbschein substitutes for it at the land registry.

5. Document the whole process identically for both sides — the same list of heirs, the same shares, the same evidence. Discrepancies between the German and Turkish documents (for example, from forced heirship / saklı pay claims that change the shares in Turkey) reliably create the longest delays with both authorities.

8. Common Mistakes in Cross-Border Document Presentation

Mistake 1: Presenting a German Erbschein at the Turkish land registry without checking first. The Tapu Müdürlüğü refuses it regardless of apostille or translation — costing time and often the expense of a second, correctly structured attempt.

Mistake 2: Presenting the Turkish certificate at a German Grundbuchamt without checking whether a Fremdrechtserbschein is needed. Some land registry offices then request supplementary documents, significantly delaying the process.

Mistake 3: Missing or outdated apostilles. Apostilles generally do not expire, but some banks require the underlying documents (e.g. the death certificate) to be recently issued — clarify this with the receiving institution in advance.

Mistake 4: Assuming the ECS will help with Turkish assets. The European Certificate of Succession only has effect within the EU — it is useless for Turkey.

Mistake 5: Not reconciling the heir lists across both countries. If the German and Turkish certificates show different inheritance shares (often due to Turkish forced heirship / saklı pay rules), the resulting contradictions can stall both procedures at once.

9. Two Real-World Scenarios: How Recognition Actually Plays Out

Scenario A: Turkish Deceased, Daughter in Germany, an Apartment in Izmir Plus a Bank Account in Cologne

Ms. Y. loses her father, a Turkish national who was last resident in Cologne. He leaves an apartment in Izmir and a bank account at a Cologne savings bank. Ms. Y. instructs a German notary for the German Erbschein procedure covering the account, and Doğru Kanzlei for the Turkish inheritance certificate procedure covering the apartment, at the same time.

Result in practice: For the Cologne bank account, the German Erbschein is sufficient on its own — there is no need to route anything through Turkey, since the account is located in Germany and Ms. Y. is unrestrictedly entitled to inherit there. For the Izmir apartment, there is no way around the Turkish inheritance certificate: Doğru Kanzlei applies for it in parallel at the competent Sulh Hukuk Mahkemesi, so both procedures run simultaneously and the Turkish inheritance tax filing deadline (6 months, since the heir lives abroad) isn't missed while waiting for the German Erbschein.

Scenario B: German Deceased, Son in Munich, a Holiday Home in Antalya

Mr. M., a German citizen with no Turkish background, inherits a holiday home in Antalya from his late father. He holds an apostilled German Erbschein with a certified Turkish translation.

Result in practice: The Turkish land registry does not accept the apostilled German Erbschein alone as sufficient proof. Doğru Kanzlei, acting under a special power of attorney issued at the Turkish consulate in Munich, applies directly to the competent Sulh Hukuk Mahkemesi on Mr. M.'s behalf — submitting the German Erbschein, the death certificate, and other evidence as supporting documentation to obtain the Turkish inheritance certificate. Only once this Turkish certificate is in hand does the land registry transfer via WEBTAPU become possible.

⚠️ Important: In both scenarios, what determines which document is needed is not the nationality of the deceased or the heir — it's exclusively the type and location of the specific asset. This distinction is routinely confused in practice and causes months of avoidable delay.

10. Cross-Border Inheritance Certificate Matters — with Doğru Kanzlei

Doğru Kanzlei holds dual bar membership with the Ankara Bar Association (registration no. 47068) and the Karlsruhe Bar Association (§ 207 BRAO). We coordinate the Turkish side of your case directly through UYAP — the inheritance certificate application, land registry transfer via WEBTAPU, correspondence with Turkish banks — and work closely with independent German notaries and specialist inheritance lawyers on the German-side procedure (probate court, Grundbuchamt, Fremdrechtserbschein), so that the two documents ultimately fit together without contradiction.

Already hold a certificate from one country and unsure whether it works in the other? Tell us briefly what you're dealing with, and we'll work out together what additional document you need and the fastest way to get it.

Request a WhatsApp Assessment of Your Inheritance Certificate

11. Special Case: Multiple Heirs, Co-Heirs Abroad, and Disputed Shares

The recognition question becomes noticeably more complex once more than one heir is involved, or the shares themselves are disputed — a common situation in Turkish-German families with children from more than one marriage, or with claims arising under Turkish forced heirship (saklı pay) rules.

Co-heirs who cannot or will not appear in Turkey: The Turkish inheritance certificate procedure generally requires formal notice to all parties involved. If co-heirs live in Germany, the process extends by the notice periods involved — but with a power of attorney, your lawyer can act for all heirs living abroad without requiring their personal presence.

Diverging shares between German and Turkish law: German and Turkish succession law apply different forced-heirship/Pflichtteil rules. The shares shown on a German Erbschein can end up differing from the shares later confirmed on a Turkish inheritance certificate — because the Turkish court independently assesses, under MÖHUK, which law applies to which asset, and can reach a different result than the German probate court did. In these situations, careful coordination between the German and Turkish procedures is essential before either document is presented to a bank or authority.

Contested inheritances: If one co-heir disputes another's status as heir (for example, through a tenkis lawsuit challenging a violation of the forced-heirship share), the Turkish authority will typically postpone issuing the certificate until the dispute is resolved by a court, or issue a provisional certificate that can later be corrected. Having a German Erbschein already in hand does not change this — Turkish courts assess succession independently under Turkish law.

Also Available in Other Languages

This guide is also available in Turkish:

Mirasçılık Belgesi Almanya'da Geçerli mi? →

And in German for German-speaking family members or advisers:

Türkischer Erbschein in Deutschland, deutscher Erbschein in der Türkei →

How to obtain the Turkish inheritance certificate in the first place — notary vs. court, power of attorney, apostille, costs — is covered in our complete inheritance certificate guide. For the tax side of a cross-border estate, see our article on Turkish inheritance tax double taxation. For the power of attorney you'll need for either process, see Power of Attorney in Turkish.

Frequently Asked Questions

Is a Turkish inheritance certificate automatically valid in Germany?

Not automatically in a formal sense, but with an apostille and a certified German translation it is generally accepted in practice by German banks for account matters. For real estate on the land registry, a Fremdrechtserbschein under § 2369 BGB is often additionally required.

Is a German Erbschein automatically valid in Turkey?

No. For Turkish real estate, the land registry accepts only a Turkish inheritance certificate. For bank accounts, Turkish banks generally require either a Turkish certificate or formal court recognition (tanıma/tenfiz) as well.

Does a European Certificate of Succession help with Turkish assets?

No. The ECS is based on the EU Succession Regulation, which applies only between EU Member States. Turkey is not an EU Member State and is not bound by it.

What is a Fremdrechtserbschein and when do I need one?

A Fremdrechtserbschein (§ 2369 BGB) is an Erbschein issued by a German probate court under Turkish law. It's most relevant when a Turkish deceased leaves movable or immovable assets in Germany and a German authority requires a document in the customary German procedural form.

Which law decides who actually inherits — German or Turkish?

Under Turkish private international law (MÖHUK Art. 20), movable assets are generally governed by the deceased's national law; real estate in Turkey is always governed by Turkish law under the location principle, regardless of nationality.

Can I apply for both certificates at the same time?

Yes, and this is explicitly recommended. With the right powers of attorney, the Turkish and German processes can run in parallel, which saves time — especially given Turkish inheritance tax filing deadlines.

Is the apostille alone enough, without a translation?

No. An apostille and a certified translation are usually two separate requirements — the apostille confirms the authenticity of the signature/seal, while the translation makes the document usable in substance for the receiving authority.