Dual Citizenship and Inheritance: Legal Framework Between Germany and Türkiye (Doppelte Staatsangehörigkeit und Erbrecht)
Cross-border matters concerning dual citizenship and inheritance between Germany and Türkiye are highly technical and sensitive areas that require evaluating two different legal systems simultaneously. Germany’s recent reforms on dual citizenship, Türkiye’s inheritance distribution rules, and the cross-border applicability of the German Civil Code (BGB) make it essential for individuals to receive professional legal guidance in order to properly manage both their assets and citizenship status. Understanding rights and obligations in both countries, avoiding procedural mistakes, and preventing loss of rights are only possible with the support of an experienced attorney.
The Impact of Dual Citizenship on Inheritance Law
Dual citizenship means that an individual is subject to the legal systems of two countries at the same time. This situation naturally creates complexities in inheritance law. Germany and Türkiye adopt fundamentally different approaches to inheritance. For example, Türkiye has strict rules regarding statutory heirs, inheritance shares, and reserved portions. Germany, on the other hand, offers broader testamentary freedom, and the distribution of an estate can vary depending on specific circumstances. Therefore, in cases involving the death of a dual citizen, issues such as the applicable legal system, the location of assets, and inheritance taxation must be evaluated carefully and managed with professional guidance.
Key Differences Between Inheritance Distribution in Türkiye and Germany
Since the two countries rely on different principles, individuals holding assets in both jurisdictions or dual citizens often face technically complex processes.
Reserved Portion (Saklı Pay / Pflichtteil)
Türkiye has a strong reserved portion system that significantly limits the testator’s freedom of disposition. Germany also recognizes the Pflichtteil system; however, it is more flexible compared to Türkiye.
Testamentary Requirements
Both countries accept wills, but their formal requirements, validity conditions, and place-of-execution rules differ. A will that is valid in one jurisdiction may be considered invalid in the other if prepared incorrectly.
Inheritance Taxation
In Türkiye, inheritance tax applies to all heirs. In Germany, however, the tax burden depends heavily on the heir’s degree of kinship, and tax rates vary based on the total value of the estate.
Common Challenges in Cross-Border Inheritance Between Germany and Türkiye
Most international inheritance disputes stem from the determination of the competent court, identification of the applicable law, administrative procedures in each country, and cross-border transfer of assets. The reintroduction of dual citizenship in Germany and the growing assets of Turkish citizens living in Germany have further increased the complexity of these processes. At this point, working with an attorney who is well-versed in both German and Turkish law ensures that inheritance procedures are fast, accurate, and fully compliant with legal requirements.
Why Professional Legal Support Is Essential
Dual citizenship and inheritance matters involve national laws from both countries as well as international private law rules. Therefore, managing the process correctly and protecting the rights of all parties requires professional guidance from an experienced law firm. Attorney Fatma Karakülah—registered with the Istanbul Bar Association since 2010, certified mediator, trademark attorney, and sworn English–Turkish translator—and the team of Turkius Law & Mediation & IP Services provide comprehensive support for inheritance and citizenship processes between Germany and Türkiye. With active offices in Türkiye, Germany, and Switzerland, and a strong legal network in more than 70 countries, the firm delivers reliable and solution-focused services in all cross-border legal matters, including inheritance and citizenship applications.
The Value Offered by Turkius Law
Turkius Law provides professional consultancy in dual citizenship matters, inheritance procedures, international estate administration, will preparation, and the recognition and enforcement of inheritance-related decisions. Additionally, the firm offers legal services in immigration law, commercial law, intellectual property, mediation, investment consultancy, and many other fields, ensuring a holistic legal approach for its clients. This comprehensive service model enables Turkius Law to deliver strong, reliable, and efficient solutions for individuals residing in both Germany and Türkiye.
