Dubai – Türkiye – Istanbul Lawyer: Enforcing Dubai Judgments, Property, Inheritance, Divorce and Debt Recovery

Turkish citizens and companies that live, work or invest in Dubai often deal with two legal systems at once. A decision may be issued by the Dubai Courts, the DIFC Courts or an arbitral tribunal, yet the practical result is needed in Turkey: at the land registry, the population registry or the enforcement office. The reverse also applies: a Turkish judgment may be needed against assets located in Dubai.

Maya Avukatlık Bürosu (Maya Law Office) operates in Kartal, on the Anatolian side of Istanbul. The office has no branch in Dubai; where necessary it cooperates with UAE-licensed counsel and foreign firms. It also handles Turkish files for Turkish citizens living abroad and for foreign clients. Services are provided in Turkish and English.

Recognition and Enforcement of Dubai Judgments in Turkey

A judgment issued by the Dubai Courts or the DIFC Courts does not take effect in Turkey on its own, even if it is final. A competent Turkish court must issue a recognition or enforcement decision. The procedure is regulated by Articles 50 to 59 of Law No. 5718 (MÖHUK).

Recognition vs. Enforcement

• Recognition: the judgment is accepted in Turkey as res judicata or conclusive evidence, for example so that a Dubai divorce is also valid in Turkey.
• Enforcement: the judgment becomes enforceable in Turkey, for example a commercial debt or alimony award that can be pursued through an enforcement office.
• An enforcement decision also covers recognition.
• A Turkish court does not re-examine the merits of the Dubai judgment; it only checks whether the conditions for recognition and enforcement are met.

Competent Court

• The court of first instance with general civil jurisdiction (asliye hukuk mahkemesi) is generally competent (MÖHUK Art. 51). In family law matters, the family court is competent.
• Venue is generally the defendant's place of residence in Turkey. If the defendant has no residence in Turkey, the courts of Ankara, Istanbul or Izmir may come into play.
• Anyone with a legal interest in enforcement may file a petition (MÖHUK Art. 52).

Conditions, Required Documents and Reciprocity for a Dubai Judgment

Conditions (MÖHUK Art. 50 and 54)

• The judgment must be issued by a UAE court in a civil matter. Personal-rights parts of criminal judgments may also be subject to enforcement.
• The judgment must be final under the law of the place where it was issued.
• Reciprocity must exist: a treaty with the UAE, statutory reciprocity or reciprocity in practice must be shown (MÖHUK Art. 54). It is not required for recognition (Art. 58).
• The subject must not fall within the exclusive jurisdiction of Turkish courts.
• The judgment must not be manifestly contrary to Turkish public order.
• The defendant's right of defence must have been respected.

Proving reciprocity is one of the points examined most closely for UAE judgments. Decisions of the Turkish Court of Cassation (Yargıtay) also guide the review of these conditions.

Required Documents

• Original or certified copy of the Dubai judgment
• Certificate or annotation showing that the judgment is final
• Sworn Turkish translation (Dubai Courts proceedings are conducted in Arabic, so judgments are mostly in Arabic; DIFC judgments are in English)
• Power of attorney, identity and address details

Time Limits

Rather than relying on a fixed rule, each file is assessed by considering the date the judgment became final, limitation periods and the state of the evidence. Delay may cause documents to become outdated and invite objections. Applying promptly after finalisation is therefore recommended. The exact time limit should be confirmed after the file is reviewed.

Enforcement Process in Turkey

Enforcing a Turkish Judgment in Dubai

A creditor who wants to enforce a Turkish judgment against assets in Dubai is subject to UAE procedural rules. Before the onshore Dubai courts, enforcement of foreign judgments is governed by Articles 222 to 225 of the UAE Civil Procedure Law (Federal Decree-Law No. 42 of 2022). Treaty provisions to which the UAE is a party take precedence (Art. 225); where there is no treaty, an application is made to the execution judge.

• The judgment must be final under the law of the country where it was issued.
• Reciprocity is required: a foreign judgment is enforced on the same conditions under which that country enforces UAE judgments (Art. 222(1)).
• The dispute must not fall within the exclusive jurisdiction of UAE courts, and the parties must have been properly summoned or represented.
• The judgment must not conflict with a UAE judgment and must not violate public order.
• The execution judge does not re-examine the merits.

Dubai Courts, DIFC Courts and Arbitration: Which Forum?

In Dubai, a dispute may go to different forums depending on the jurisdiction or arbitration clause in the contract. The choice of forum determines the language, the timeline, the cost and how the decision will be applied in Turkey.

• A clearly drafted DIFC jurisdiction clause may be treated as binding in practice; ambiguous wording may lead to a jurisdiction dispute.
• DIFC Courts judgments are executed through the Dubai courts where the assets are outside the DIFC.
• Both the UAE and Türkiye are parties to the New York Convention; where a contract has an arbitration clause, this route is often more predictable than litigation.

Reviewing the jurisdiction and arbitration clause before signing reduces later disputes over the forum.

Buying Property in Dubai, Off-Plan Sales and Title Deed Matters

In Dubai, foreigners may acquire property in designated freehold areas under Dubai Law No. 7 of 2006 and related regulations. Title is registered at the Dubai Land Department (DLD). For off-plan purchases, the sale contract is registered through the Oqood system, and buyer payments must be held in a RERA-approved escrow account under Dubai Law No. 8 of 2007. Fees, charges and acquisition rules may change, so current conditions should be confirmed at the time of the transaction.

Pre-Purchase Checklist

• RERA/DLD registration of the project and developer, and the escrow account details
• Terms of the sale and purchase agreement (SPA) and the payment plan
• Handover date, delay and termination provisions
• Nature of the title deed or Oqood record, and any mortgage or annotation on the property
• Service charges, fees and, where relevant, the rental (Ejari) plan

If handover is delayed or a project is cancelled, a RERA complaint, a refund claim from the escrow account and proceedings before the Dubai courts are assessed together. For investors based in Dubai, Turkish property purchase, sale promise and title cancellation and registration files in Turkey can be handled by the office.

Debt Recovery and Enforcement Proceedings

The route a creditor takes depends on the type of document held and the location of the debtor's assets:

• Final Dubai judgment: after an enforcement decision, enforcement based on a judgment (ilamlı icra) is started in Turkey.
• Promissory note, cheque, invoice or contract: an enforcement proceeding without a judgment (ilamsız icra) is started in Turkey; if the debtor objects, an action to annul the objection is filed.
• Debtor's assets in Turkey: attachment and, where appropriate, precautionary attachment are considered.
• Debtor's assets in Dubai: a separate proceeding is planned in the UAE with local counsel.
• Arbitral award: the award is enforced in the relevant country under the New York Convention.

A foreign judgment for which an enforcement decision has been issued is enforced like a judgment of a Turkish court. To succeed in collection, the debtor's assets in Turkey (real estate, bank accounts, vehicles, receivables) should be researched in advance.

Marriage, Divorce and Custody in Dubai

Personal status matters in the UAE are governed by two systems: Federal Decree-Law No. 41 of 2024 on Personal Status for Muslims (in force since April 2025) and Federal Decree-Law No. 41 of 2022 on Civil Personal Status for non-Muslims. Which system applies depends on the parties' religion, nationality and residence status. There are also provisions under which foreigners may ask for their home-country law to apply. A divorce decree issued in Dubai may not produce effects under Turkish law until it is recognised in Turkey.

• If only the validity of the divorce is needed in Turkey, a recognition case may be sufficient.
• For custody, alimony, compensation and property regime provisions to be enforced in Turkey, an enforcement case is required.
• For certain types of decrees, administrative registration through the population registry may also be possible; the choice depends on the content of the decree and is determined file by file.
• The family court is competent. In most files, the parties can be represented by power of attorney without travelling to Turkey.

Child custody needs separate attention. The UAE is not a party to the 1980 Hague Child Abduction Convention, while Türkiye is. There is therefore no automatic treaty-based return mechanism. If there is a risk that a child may be taken abroad, preventive steps should be sought without delay.

Inheritance, Wills and Assets in Turkey

The estate of a person with assets in both Dubai and Turkey sits where two legal systems meet. Under MÖHUK Article 20, succession is generally governed by the national law of the deceased, but Turkish law applies to immovables located in Turkey. Assets in Dubai are dealt with under UAE law and before UAE courts. A single document or a single case may therefore not resolve the entire estate.

Wills of Non-Muslims in Dubai

• Dubai Law No. 15 of 2017 regulates wills and estate administration for non-Muslims in Dubai.
• Wills may be registered with the non-Muslim wills registry at the Dubai Courts or the DIFC Courts.
• For Muslims, the Sharia-based UAE personal status rules come into play; the applicable law depends on the religion of the deceased, the existence of a will and the location of the assets.

Common Inheritance Files

• Transfer of immovables in Turkey to heirs (certificate of inheritance, Turkish Civil Code Art. 598)
• Use of a Dubai will or inheritance document in Turkey
• Annulment of a will and reduction actions (tenkis) for forced-heirship violations
• Claims of sham transfers to defeat heirs (muris muvazaası)
• Termination of co-ownership among heirs

Whether a Dubai will or inheritance document is accepted for land registry and banking procedures in Turkey depends on formal requirements, certification and translation. Because Turkish courts may have jurisdiction over matters involving Turkish immovables, a foreign document may not be accepted directly. Review of the file before taking any step is recommended.

Practice Areas

Maya Avukatlık Bürosu provides legal support in the following areas for Dubai–Türkiye files:

In criminal matters, judicial assistance and extradition between Türkiye and the UAE are assessed separately for each file.

Istanbul-Based Services and Cooperation with Foreign Firms

Maya Avukatlık Bürosu operates in Kartal, on the Anatolian side of Istanbul. The office serves Turkish citizens living abroad and foreign clients in their Turkish files. Services are provided in Turkish and English.

The office has no branch in Dubai. Because proceedings before the Dubai courts are handled by UAE-licensed lawyers, cooperation with UAE counsel can be arranged where necessary. Such cooperation is set up according to the nature of the file and with the client's knowledge.

The following documents are usually enough for an initial assessment:

• The Dubai court judgment, or a copy of the case file if available
• Identity or passport details
• Title deed, SPA, Oqood record or will
• Correspondence between the parties and payment records

You can send your documents through the contact page.

Dubai – Türkiye Legal Relations: 17 Common Issues

1. Managing Dubai and Turkish Cases under Private International Law

MÖHUK determines the competent court, the applicable law and the recognition and enforcement of judgments in cross-border disputes. For Dubai–Türkiye files, UAE procedural rules and bilateral treaties are added. Each file starts with three questions: Which country's court or tribunal is competent? Which country's law applies? Can the decision be recognised and enforced in the other country?

2. Dubai Courts or DIFC Courts? The Importance of the Jurisdiction Clause

The jurisdiction or arbitration clause is the most important factor in determining the forum. Clauses that expressly refer to the DIFC may be treated as binding, while ambiguous wording can lead to a jurisdiction dispute. Reviewing the clause before signing is recommended.

3. Divorce Proceedings in Dubai and Their Effect in Turkey

In the UAE, divorce may fall under different legislation depending on the parties' religion and nationality. Once final, a recognition step is needed for the decree to take effect in Turkey in terms of the population registry and the property regime.

4. Recognition and Enforcement of a Dubai Divorce Decree

Recognition is sought if only the termination of the marriage must be accepted in Turkey; enforcement is sought if alimony, custody or compensation provisions must be applied. For certain decrees, administrative registration through the population registry may also be considered.

5. Preparing the File for a Recognition and Enforcement Case

The judgment, the finality certificate, a sworn translation of Arabic judgments, a power of attorney and identity details are prepared. Because the UAE is not a party to the Apostille Convention, the certification chain is checked file by file.

6. Marriage in Dubai and Registration in Turkey

A marriage concluded abroad is generally valid if it complies with the law of the place where it was concluded. The documents and procedure for registering it in the Turkish population registry depend on how the marriage was concluded.

7. Inheritance in Dubai and Division of the Estate

Assets in Dubai (property, bank accounts, company shares) are dealt with under UAE law and before UAE courts; assets in Turkey are dealt with under Turkish law and before Turkish courts. The two groups of assets should be planned together.

8. DIFC Wills and Immovables in Turkey

Non-Muslims in Dubai may register their wills with the registry at the Dubai Courts or the DIFC Courts. For immovables in Turkey, the forced-heirship limits of Turkish law cannot be exceeded; if they are, a reduction action may follow.

9. Transfer of Inheritance and Probate Procedures in Turkey

In Turkey, a certificate of inheritance is obtained from a notary or a civil court of peace, inheritance and transfer tax procedures are completed, and then the land registry and bank transfers are carried out. In cases with a foreign element, the court route may be required.

10. Buying Property in Dubai and Freehold Areas

The areas where foreigners may acquire property are set by Dubai legislation, and title is registered at the Dubai Land Department. Before purchase, the registration of the project and seller, the nature of the title deed and any encumbrances should be checked.

11. Off-Plan Delays, Termination and Refunds

For off-plan purchases, payments should be held in a RERA-approved escrow account. If handover is delayed or the project is cancelled, a RERA complaint and proceedings before the Dubai courts are assessed together.

12. Lease Agreements and Eviction in Dubai

A lease in Dubai is subject to Dubai tenancy legislation and Ejari registration, and a separate rental disputes centre handles tenancy disputes. Lease and eviction disputes concerning property in Turkey are heard in Turkey under the Turkish Code of Obligations.

13. Company Formation and Partner Disputes in Dubai

A company may be set up onshore (mainland) or in a free zone; the applicable rules and the competent court depend on the place of incorporation and the contract. In disputes between Turkish partners, share transfers, the shareholders' agreement and the jurisdiction clause are reviewed together.

14. Debt Recovery, Cheque and Promissory Note Disputes

The route a creditor takes depends on the type of document and the location of the debtor's assets. In Turkey, enforcement without a judgment, an action to annul the objection and precautionary attachment may apply; in Dubai, a proceeding with UAE counsel is planned.

15. Employment Issues for Turkish Workers in Dubai

UAE labour legislation contains its own rules, such as end-of-service gratuity. In cases filed in Turkey, the applicable law and jurisdiction are determined under MÖHUK.

16. Child Custody and Removal of a Child Abroad

The UAE is not a party to the 1980 Hague Child Abduction Convention, so there is no automatic treaty-based return mechanism. Enforcement is required for a custody decision to be applied in Turkey. If there is a risk that a child may be taken abroad, preventive steps should be sought without delay.

17. Travel Bans and Criminal Investigations

In Dubai, a debt, cheque or complaint may lead to a travel ban or a criminal investigation. These files are handled in coordination with local UAE counsel. Türkiye and the UAE have signed treaties on judicial assistance in criminal matters and on extradition; their entry-into-force status is checked in each file.

Frequently Asked Questions