Many people with ties to Didim have made significant investments here. You may own a holiday home, have bank accounts, maybe a car. Except for certain legal situations like a debt or an outstanding divorce case, while you’re still living and breathing you can dispose of your assets as you want: sell them, keep them, give them away.

But if you pass away, there are laws in Türkiye governing inheritance, and those laws apply to foreign nationals as well as Turkish citizens. The most relevant is the difference between movable and immovable assets. Immovable assets generally mean property or anything fixed to the ground (or the ground itself), that can’t be moved without fundamentally changing its value. Movable assets are things like bank accounts, stocks and shares, cars, where the physical location isn’t integral to the value.

If you are a foreign national with property, bank accounts or other assets in Türkiye, the inheritance system in Türkiye can seem complicated. There is a formula that applies to who automatically inherits immovable property if someone doesn’t leave a will (zümre), and another formula (saklı pay) which applies to ensure certain family members inherit a minimum share, even if there’s a will that says otherwise.

ZÜMRE – Legal inheritance shares of family members surviving the deceased if there is no will

Spouse and children → Spouse receives ¼; children share ¾ equally
Children, no spouse → Children share 100% equally
Spouse and parents (or qualifying descendants of deceased parents) → Spouse receives ½; the other family group shares ½
Parents, no spouse or children → Parents inherit equally; a deceased parent’s descendants may take that parent’s place
Spouse and grandparents’ family group → Spouse receives ¾; qualifying relatives share ¼
Spouse, with no qualifying relatives in the preceding groups → Spouse inherits 100%
No qualifying heirs → The estate passes to the state

SAKLI PAY MİRASCI – Even if you leave a will to the contrary, under Turkish law, spouse, children and surviving parents are all protected heirs and legally must inherit at least 50% of their standard zümre entitlement.

Which country’s law applies?

Turkey’s Law No. 5718 on Private International Law says that inheritance is generally governed by the deceased person’s national law. However, it makes a specific exception for immovable property located in Türkiye, which is governed by Turkish law. In simple terms, for a British national this can mean two different legal systems operating within the same estate:

• A house or other immovable property in Türkiye: Turkish inheritance law applies.
• Movable assets in Türkiye: The deceased’s national law generally applies. For a British citizen, the precise UK law involved needs to be established according to their circumstances and relevant UK jurisdiction; it should not simply be assumed that “UK law” means the same thing for everyone.
• Assets in the UK: These will normally be dealt with through the appropriate UK legal and probate system rather than being transferred through the Turkish Land Registry.

Let’s take an example that might be relevant to a lot of expats living in Didim: what if you’re British, own your home and a car in Türkiye and live with your partner of 20 years, but also have living relatives, for instance adult children from a previous relationship? You want your partner to keep your property in Türkiye worth 10,000,000 TL, your car worth 1,500,000 TL, and most or all of the contents of your bank accounts, containing 5,000,000 TL. There is no such thing as a “common-law spouse” with automatic inheritance rights in Türkiye. So, if you want your partner to inherit, what can you do?

For the Turkish property, Turkish law applies. Under the Turkish Civil Code, children are first-degree legal heirs and inherit equally. With two children, no surviving spouse recognised by Turkish law, and no other legal heirs, each child would normally receive a 50% share. Children are also saklı paylı mirasçı, heirs whose minimum share is protected by law. The protected share of such a descendant is half of their normal legal inheritance share. Their protected saklı pay is therefore 25% each.

That means that, in this simplified example: Child 1: protected share = 25%, Child 2: protected share = 25%, Total protected children’s share = 50%, Disposable portion = 50%. Consequently, you can potentially leave the remaining 50% of the Turkish property to your partner in a will.

When it comes to the car and bank accounts, if the relevant national law is English law, for example, there is generally much greater testamentary freedom than under Turkish forced-heirship rules. That means a properly drafted will may be able to leave the relevant movable assets entirely to the partner.

Using our example:

Turkish house – 10,000,000 TL. Partner can receive up to 5,000,000 TL; children retain protected shares
Car – 1,500,000 TL. Potentially 100% to partner
Bank accounts            – 5,000,000 TL. Potentially 100% to partner
Total value of inheritance – 16,500,000 TL; Potentially 11,500,000 TL to partner

So, the partner could potentially receive around 69.7% of this particular Turkish estate, while the children retain the 5,000,000 TL protected portion of the house. But this is an illustration, not a universal formula. The applicable UK law, domicile, debts, ownership arrangements and the exact nature and location of the assets can all affect the result.

Don’t forget the tax

Türkiye has its own Veraset ve İntikal Vergisi (Inheritance and Gift Tax), and the tax treatment depends on the relationship between the deceased and the beneficiary. For 2026, the inheritance-tax exemption for each child or spouse is 2,907,136 TL. The exemption is not available to an unmarried partner or any other inheritor, who will be liable for 10% to 30% tax on their entire inheritance, depending on the value.

What if you already have a will in the UK?

If you have an English will, it cannot override the Turkish saklı pay rights applying to your house in Türkiye, but it may be effective for assets governed by the relevant English law – car, bank accounts, personal effects.

We consulted Sami Işık, Didim-based legal consultant and translator, who confirmed that your UK will should be translated and notarised in Türkiye, and that it will need to be recognised and enforced by Turkish courts before your executor can disperse your assets. You should make sure that your wishes regarding property in Türkiye comply with the saklı pay rights. Have the will reviewed by both a UK wills/probate specialist and a Turkish lawyer familiar with international inheritance if there are any grey areas.

I have children who have a legal right to inherit part of my property. Can I grant my partner the right to stay in it?

Potentially, yes. In this case a usufruct (intifa hakkı) may be worth discussing with a Turkish lawyer. A usufruct can give the partner a right to use and enjoy the property while ownership itself is held by others.

A few other things foreign property owners should think about

Inheritance planning isn’t just about writing a will. It is worth keeping a file containing:

• Your current will or wills.
• A list of Turkish properties and their Tapu details.
• Turkish and foreign bank-account details.
• Vehicle ownership documents.
• Details of insurance policies and beneficiaries.
• Copies of passports and identity documents.
• Marriage, divorce and birth certificates where relevant.
• Contact details for your UK solicitor and Turkish lawyer.
• Information about any debts or mortgages.
• Details of anyone who should be contacted after your death.

It is also worth making sure your family knows where the documents are. A beautifully drafted will is considerably less useful if nobody can find it.

Finally

If you own property in Türkiye, don’t leave your estate planning to your loved ones. Make a will and make sure you understand the implications of Turkish law on property inheritance.

This article is intended as general information for Voices readers, not as legal or tax advice. International inheritance law can be particularly complex, and the rules and tax rates can change. Anyone with property or other assets in Türkiye should obtain individual advice from a suitably qualified Turkish lawyer and, where appropriate, a lawyer in the relevant overseas jurisdiction.