Certificate of Inheritance Translation for France

The notaire and the acte de notoriété

When a succession opens in France, the document that identifies the heirs and their capacities, the acte de notoriété, is drawn up by a notary without any separate probate court process. Where a Turkish certificate of inheritance is to serve as the basis for that process, the notaire reads the heirs and the share proportions from the translation; the spelling of names, the degrees of kinship and the fractions are therefore preserved exactly. The certificate is not equated with an acte de notoriété; the name of the issuing authority (civil court of peace or notary) and the numbers are carried over in their original form, because the notaire will be transferring that information into the document he or she draws up.

The heirs’ share proportions are usually written as fractions, and they are the most delicate point in the translation; a single digit out of place in one share upsets the whole distribution. The proportions are not turned into decimals and not rounded; they are carried over exactly as the document has them. Bringing the terms of kinship closer to French concepts makes it arguable who inherits in what capacity.

Because a succession in France usually requires the involvement of a notaire above a certain threshold, the Turkish certificate is one of the basic documents submitted at the start of the process; the notary reads the heirs and their shares from it and builds his or her own document on that footing. It matters, then, that the translation should leave no doubt at the notaire’s first reading of the file. What the document is to be used for, whether a bank, immovable property or insurance, also determines which annexes are translated with it.

Réserve héréditaire and the applicable law

The reserved portion (réserve héréditaire) is a powerful institution in French succession law; assessing how the shares in a Turkish certificate stand in relation to it is the business of the notaire and a lawyer, not of the translator. The translator carries the shares and capacities in the certificate over as they stand and adds no comment on whether they conflict with the reserved portion. In the same way, which law applies to an estate connected with France, judged by habitual residence or the location of immovable property, is for the notary and the lawyer to assess; the translation prepares the ground for that assessment.

Since the reserved portion also sets the limit of what may be disposed of by will, where the deceased has left a will the certificate is assessed alongside that expression of intent; the two documents are not, however, confused with one another. The certificate shows the heirs and their shares while the will carries the intention, and translating both with the same terms and the same spelling of names allows the notaire to keep contradictions in the file to a minimum. In such cases keeping it clear in the translation which document performs which function strengthens the footing of the process.

In the file the certificate is usually submitted together with a civil registry extract and the death certificate; where a transaction concerns immovable property, the title deed details are added as well. Consistency of names and dates across these documents is what allows the notaire to assess the file as a whole.

Succession matters in France are often tied to strict timetables and reporting obligations, so preparing the document early carries weight; a certificate translated incompletely or late can hold up the acte de notoriété the notaire is to draw up and the steps that follow from it. Where the estate touches immovable property in France, it is worth knowing from the start that the transfer of that property will likewise go through a notary; the translation of the certificate is then planned not for a single transaction but with the whole chain of connected steps in view.

Court-of-appeal listed translators and the order of certification

A translation submitted for official use in France must be made by a sworn translator (traducteur assermenté) on the list of a court of appeal (Cour d’appel); in a translation produced in Türkiye, a sworn translator signs it, it is notarised where required, and an apostille is added. Confirming with the notaire which route will be accepted is the safest step.

• Do not equate the certificate with an acte de notoriété; carry the name of the authority over in its original form.
• Convey the share fractions exactly; add no interpretation of the réserve héréditaire.
• Confirm with the notaire whether the listed assermenté route or the Türkiye chain applies.

France is a party to the Hague Apostille Convention; for a judicial or notarial document the apostille is obtained from the relevant judicial justice commission, and the current position should be confirmed from the official HCCH list. You can run your file through our single office in Kızılay, Ankara, see the cost on our pricing page and upload your document to request a quote. This page is for general information and does not take the place of legal advice; for the succession consult a notaire and your lawyer.