Qatar – Türkiye – Istanbul Lawyer: Enforcing Qatari Judgments, Inheritance, Divorce, Employment and Property Matters

Turkish citizens and foreign nationals who live, work or invest in Qatar often deal with two legal systems at once. A judgment, contract or document may originate in Qatar, yet the practical result is frequently needed in Türkiye: at an enforcement office, the land registry or the population registry.

Maya Avukatlık Bürosu (Maya Law Office) operates in Kartal, on the Anatolian side of Istanbul. The office has no branch in Qatar; where necessary it cooperates with Qatari 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 Qatari Judgments in Türkiye

A judgment issued by a Qatari court does not take effect in Türkiye 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). No bilateral treaty in force on recognition and enforcement of foreign judgments in civil and commercial matters between Türkiye and Qatar has been identified. The review therefore runs on the general MÖHUK conditions, with reciprocity examined separately.

Recognition vs. Enforcement

• Recognition: the judgment is accepted in Türkiye as res judicata or conclusive evidence, for example so that a Qatari divorce is also valid in Türkiye.
• Enforcement: the judgment becomes enforceable in Türkiye, for example an alimony or debt 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 Qatari 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 Türkiye. If the defendant has no residence in Türkiye, 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, Document Chain and Time Limits

Conditions (MÖHUK Art. 50 and 54)

• The judgment must be issued by a Qatari 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. It is not required for recognition (MÖHUK 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.

Required Documents

• Original or certified copy of the Qatari judgment
• Certificate or annotation showing that the judgment is final
• Sworn Turkish translation (an Arabic-to-Turkish translation if the judgment is in Arabic)
• 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 Türkiye

Enforcing Turkish Judgments in Qatar

Applying a Turkish judgment in Qatar is handled under Qatar's Judicial Enforcement Law (Law No. 4 of 2024). The law adopts the principle of reciprocity for foreign judgments and orders (Art. 13), sets formal conditions for enforcing foreign judgments (Art. 15) and establishes the Enforcement Court that conducts enforcement (Art. 2).

• If reciprocity is challenged, the burden of showing it may fall on the applicant. The fact that Turkish law allows enforcement of foreign judgments matters in that showing.
• Proceedings before Qatari courts are conducted in Arabic, so the judgment and its annexes need an Arabic translation.
• Turkish documents may need an attestation chain and legalisation by a Qatari mission before use in Qatar.
• Steps in Qatar generally require Qatari-licensed counsel.

Inheritance and Wills Involving Qatar

The estate of a person with assets in both Qatar and Türkiye 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 Türkiye. For assets in Qatar, the jurisdiction of Qatari courts and Qatari law come into play.

In Qatar, family and inheritance disputes are heard by the Family (Sharia) Court. For Muslims, the Family Law (Law No. 22 of 2006) and Islamic-law shares apply; non-Muslim foreigners may ask for the law of their home country to be applied. Shares may differ from those under the Turkish Civil Code.

Common Inheritance Files

• Bank accounts, property and employer receivables in Qatar of a Turkish citizen who has died there
• Transfer of immovables in Türkiye to heirs (certificate of inheritance, Turkish Civil Code Art. 598)
• Use of a Qatari will or certificate of inheritance in Türkiye
• Reduction actions (tenkis) for forced-heirship violations
• Termination of co-ownership among heirs

Whether a document issued in Qatar is accepted for land registry and banking procedures in Türkiye depends on formal requirements, the attestation chain and translation. Review of the file before taking any step is recommended.

Validity of a Qatari Divorce in Türkiye

Divorce in Qatar is governed by the law determined by the parties' religion and nationality. The Family Law applies to Muslims; non-Muslim foreigners may request the application of their home-country law. A divorce issued in Qatar may not produce effects under Turkish law until it is recognised in Türkiye.

• If only the validity of the divorce is needed in Türkiye, a recognition case may be sufficient.
• For custody, alimony, compensation and property regime provisions to be enforced in Türkiye, an enforcement case is required.
• Divorces effected by unilateral declaration or an administrative act rather than a court judgment are examined separately for their status as a "court judgment" under MÖHUK and for public order; the outcome depends on the file.
• The family court is competent. In most files, the parties can be represented by power of attorney without travelling to Türkiye.

Employment in Qatar, End-of-Service Gratuity and Labour Claims

Private-sector employment in Qatar is governed by Labour Law No. 14 of 2004. Decree-Law No. 18 of 2020 removed the requirement for the employer's consent (NOC) to change employers. Law No. 9 of 2026 has restructured the procedure for employment disputes.

End-of-Service Gratuity

• A worker with at least one year of service is entitled to an end-of-service gratuity of no less than three weeks' basic wage for each year of service (Labour Law Art. 54). Part years are calculated pro rata.
• Because the calculation is based on basic wage, the split between basic pay and allowances in the contract directly affects the result.
• This payment is not identical to Turkish severance pay (kıdem tazminatı); the conditions and calculation method are reviewed separately.

Labour Dispute Procedure (Law No. 9 of 2026)

Buying Property in Qatar

Property acquisition by foreigners in Qatar is limited to the areas set by Law No. 16 of 2018 and Council of Ministers decisions. There are two main rights: freehold ownership and a renewable usufruct right of up to 99 years. Freehold is available in designated areas such as The Pearl and Lusail. Purchases above a certain value may also open a property-linked residence permit, subject to a value threshold and a minimum annual stay. As area lists and thresholds may change, current conditions should be confirmed at the time of the transaction.

Pre-Purchase Checklist

• Whether the area and the exact plot or unit number are open to foreign ownership
• Whether the right sold is freehold or usufruct, and whether the unit has its own title deed
• Whether there is a mortgage, attachment or annotation on the property
• Terms of the sale contract, the payment plan and transfer conditions
• Developer and contract terms for off-plan purchases; outstanding service charges
• If a power of attorney is used, the attestation chain for that document

Disputes arising from sale and construction contracts may lead to claims for termination, refund of amounts paid or compensation.

Debt Recovery, Cheques, Companies and Arbitration

The route a creditor takes depends on the type of document held and the country where the debtor's assets are located:

• Final Qatari judgment: after an enforcement decision, enforcement based on a judgment (ilamlı icra) is started in Türkiye.
• Promissory note, cheque, invoice or contract, with assets in Türkiye: an enforcement proceeding without a judgment (ilamsız icra) is started in Türkiye; if the debtor objects, an action to annul the objection is filed.
• Debtor's assets in Qatar: a separate proceeding is planned in Qatar. Under Law No. 4 of 2024, cheques and lease contracts can, under certain conditions, serve as enforcement instruments.
• The same law empowers the enforcement judge to order measures against a debtor, such as a travel ban. This possibility should be considered separately for anyone with debts in Qatar.
• A bounced cheque may carry criminal consequences under Article 357 of the Qatari Penal Code. The current provision should be confirmed before any step is taken.

Security for Costs (MÖHUK Art. 48)

Company Formation and Foreign Investment

Foreign-owned companies in Qatar are formed under Foreign Investment Law No. 1 of 2019. In most sectors, up to 100% foreign ownership is possible, subject to approval by the relevant ministry. Separate rules apply to areas such as banking, insurance and commercial agency.

Arbitration

Qatar acceded to the New York Convention in 2002 and applies Arbitration Law No. 2 of 2017. Türkiye is also a party to the New York Convention. For contracts with an arbitration clause, recognition and enforcement of awards follow a regime separate from court judgments, so the choice of dispute resolution forum matters at the drafting stage.

Practice Areas

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

In criminal matters, the mutual legal assistance agreement signed with Qatar in Doha on 15 November 2017 also covers extradition, transfer of sentenced persons and transfer of criminal proceedings. Its status in force and its application 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 Qatar. For steps that must be taken before Qatari courts, cooperation with Qatari 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 Qatari judgment, employment contract, or a copy of the case file if available
• Identity or passport details, and Qatar ID (QID) details if any
• Title deed, sale contract or will
• Correspondence between the parties, salary and payment records

You can send your documents through the contact page.

Qatar – Türkiye Legal Relations: 17 Common Issues

1. Managing Qatari 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. Each file starts with three questions: Which country's court is competent? Which country's law applies? Can the judgment be recognised and enforced in the other country?

2. Divorce Proceedings in Qatar and Their Effect in Türkiye

A divorce case filed in Qatar is heard under the law determined by the parties' religion and nationality. Once final, a recognition step is needed for the decree to take effect in Türkiye in terms of the population registry and the property regime.

3. Recognition and Enforcement of a Qatari Divorce

Recognition is sought if only the termination of the marriage must be accepted in Türkiye; enforcement is sought if alimony, custody or compensation provisions must be applied. Whether the divorce was issued by a court or by a unilateral act matters in the public-order review.

4. Preparing the File for a Recognition and Enforcement Case

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

5. Estate of a Turkish Citizen Who Dies in Qatar

Assets in Qatar raise the jurisdiction of Qatari courts and Qatari law; assets in Türkiye are dealt with under Turkish law and before Turkish courts. The two groups of assets should be planned together.

6. Transfer of Assets in Türkiye and Probate Procedures

In Türkiye, 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.

7. Using a Qatari Will in Türkiye

The will's compliance with formal requirements, its attestation chain and its translation are checked. For immovables in Türkiye, the forced-heirship limits of Turkish law cannot be exceeded; if they are, a reduction action may follow.

8. Property in Qatar: Freehold and Usufruct

Acquisition is limited to certain areas. Whether the right bought is freehold or usufruct affects the price, transfer and how it passes by inheritance. Before purchase, the area and title details should be confirmed from official records.

9. Off-Plan Purchases and Sale Promise Contracts

For off-plan purchases, the payment plan, delivery date and the developer's obligations arise from the contract. In case of delay or breach, termination and refund claims are assessed.

10. End-of-Service Gratuity vs. Turkish Severance Pay

Under Qatari Labour Law, the end-of-service gratuity is calculated on at least three weeks' basic wage per year. The Turkish severance pay regime differs; the two systems should be reviewed separately rather than compared directly.

11. Conciliation and Committee Procedure for Labour Claims

Under Law No. 9 of 2026, disputes first go to conciliation at the Ministry and, failing that, to the Committee. The suspension of limitation periods during conciliation matters for the timing of any filing.

12. Contractor and Subcontractor Relationships in Qatari Projects

For workers employed on projects in Qatar, the identity of the employer and responsibility along the contract chain are examined file by file. Contracts between the main contractor, subcontractor and employer are important evidence.

13. Cheques, Promissory Notes and Debt Recovery

In Qatar, a cheque may have consequences both as an enforcement instrument and in terms of criminal liability. In Türkiye, a creditor may choose enforcement based on a note or enforcement without a judgment. The location of the debtor's assets shapes the route.

14. Company Formation and Foreign Investment in Qatar

The Foreign Investment Law allows a high level of foreign ownership in most sectors. The ownership structure, contract language and dispute resolution forum should be settled at the formation stage.

15. Arbitration and Enforcement of Awards

Qatar and Türkiye are both parties to the New York Convention. For contracts with an arbitration clause, enforcement of an award in the two countries follows separate rules and conditions.

16. Child Custody and International Child Abduction

Türkiye has been a party to the 1980 Hague Convention since 2000 (Law No. 5717). Qatar is not a party, so return claims do not run through the Convention mechanism but through Qatari domestic law and diplomatic channels. Time is critical in these cases, so action should be taken without delay.

17. Criminal Legal Assistance, Extradition and Measures Against Debtors

The 2017 criminal legal assistance agreement with Qatar also covers extradition and transfer of sentenced persons; its status in force is checked for each file. For debtors in Qatari enforcement proceedings, measures such as a travel ban may also come into play.

Frequently Asked Questions