Certificate of Inheritance (Certificate of Succession) Translation

Cross-border use arises whenever the estate touches an account, a property or a vehicle abroad. Before releasing a payment or registering a transfer, a foreign bank or land registry authority wants to see who the entitled parties are and what each of them holds – and it reads that information solely through the translation. If the shares are rendered incorrectly, an heir’s entitlement can appear smaller or larger than it really is.

Translation is not needed in every succession matter, only where the document crosses a linguistic or legal border. A transfer handled entirely within Türkiye proceeds on the Turkish original, whereas releasing an account, a property or an insurance claim abroad means having the document rendered into the language of the destination country and put through whatever certification that country asks for. The reverse case works the same way: where a succession document issued abroad is to be used for the distribution of assets in Türkiye, a Turkish translation and notarisation come into play. The first thing to establish, therefore, is the country and the authority before which the document will be used; the answer settles the language of the translation and the layer of certification together.

Court-issued or notary-issued?

The same document can come from two different authorities. A notary public may issue a certificate of inheritance where the civil registry records are clear and uncontested; if there is a dispute among the heirs or any uncertainty in the records, the certificate is obtained from the civil court of peace. Both versions can be used abroad, but which one you hold has a direct bearing on the apostille step.

The title of the document, the name of the issuing authority and the notarial register number or the case and judgment numbers are carried over unchanged. These details are the identity of the document; numerical identifiers are not translated but reproduced exactly. Rendering the name of the issuing authority loosely leaves the receiving authority uncertain about where the document actually came from.

Translating shares and fractions

At the heart of a certificate of inheritance are the shares held by the heirs, and those shares are usually expressed as fractions. A single digit out of place in one share upsets the whole distribution, which makes the exact reproduction of the fractions, their denominators and their numerators the most sensitive point of the translation. Converting the shares to decimals or rounding them is not acceptable; the document is carried across exactly as written.

The spelling of each heir’s forename and surname must match their identity documents and any records held abroad. The name of the deceased, the date of death and each heir’s family relationship to them are preserved in full. Translating the terms that describe degrees of kinship only approximately blurs the capacity in which each person inherits and casts doubt on the basis of the shares.

Estates with a foreign element

Where an estate has a foreign element, the question of which country’s law applies is a separate matter and varies from case to case. In many legal systems immovable property may be governed by the rules of the country in which it is situated, while movable property may be assessed by reference to a different connecting factor. Making that assessment is no part of the translator’s work; the translator reproduces the document as it stands, and the legal characterisation is left to the competent authority and to lawyers.

In the opposite direction, where a succession document issued abroad is to be used in a transaction in Türkiye, it is apostilled in the country of issue, then translated in Türkiye by a sworn translator and put through notarisation. The succession concepts used in a foreign document may have no exact counterpart in the Turkish system; in such cases the term is rendered so as to preserve the meaning it carries in the source text.

Annexes and accompanying documents

A certificate of inheritance rarely travels alone: a civil registry extract, a death certificate and, depending on the transaction, a power of attorney sit in the same file. Names, dates and kinship details must agree across all of them. One surname spelled differently in a single document raises the question of whose file this actually is and brings the transaction to a halt.

Where a succession concerns several heirs, each of them may need a separate certified copy for their own file. Deciding at the outset how many copies to produce is quicker than going back to apply again later. Whether the document is an electronically signed printout or a wet-signed copy should likewise be settled in advance, according to what the receiving authority expects.

Table of certification levels

Different assets within the estate

An estate may amount to far more than a bank account: immovable property, vehicles, company shares and receivables all form part of it. Each type of asset is dealt with by a different authority, and most of them call for their own supporting documents alongside the certificate of inheritance. Where the document will be used therefore also determines which annexes are translated with it; the nature of the transaction has a direct effect on the scope of the translation.

If any item in the estate lies abroad, the authority in that country will want to see the document translated into its own language and certified. The same certificate may be translated into several languages for transactions in different countries; when that happens, rendering the shares and the heirs’ names identically in every version keeps those transactions consistent with one another. A name spelled differently in one country weakens the link between that file and the rest.

A will changes the process

Where the deceased left a will, the certificate of inheritance is assessed together with that expression of intent. A will is a separate document and follows its own process of opening and registration, whereas a certificate of inheritance shows who the heirs are and what shares they hold. Confusing the two produces contradictions about who is entitled to what and leaves the transaction on hold.

Where a will drawn up abroad is involved, the document is certified in the country of issue and translated into Turkish. Translating a will and translating a certificate of inheritance call for different kinds of attention: one carries an expression of intent, the other an entitlement. Keeping both documents to the same terminology and the same spelling of names holds the file together.

Common mistakes with certificates of inheritance

• Converting the fractional shares to decimals, or rounding them.
• Translating the terms for degrees of kinship only approximately.
• Applying to the governor’s office for the apostille on a notary-issued document.
• Leaving out case and judgment numbers or notarial register numbers.
• Spelling the heirs’ names differently from their identity documents.

Let us take your succession file step by step

Succession matters often involve several countries and several authorities at once, so establishing at the outset which transaction the document is for and what certification it needs prevents delays. Once you send us the document, we plan the accurate rendering of the shares and the required chain of certification with you. You can see which certification is expected for which document in our document guide and our terms of work on the pricing page, and you can share your document through the quote form.

This page sets out the general framework; whether an apostille or notarisation is required depends on the institution you apply to. The safest course is to ask the relevant office for written confirmation before you begin.