Legal Support in Istanbul for UAE–Türkiye Cross-Border Matters
Legal matters of people who live, work or invest between the United Arab Emirates (UAE) and Türkiye sit where two legal systems meet. Enforcement of judgments, divorce and custody, inheritance, labour claims, cheques and debts, companies and property each call for the right country, the right procedure and the right order of steps. This page outlines the general framework and the areas in which Maya Avukatlık Bürosu (Maya Law Office) supports clients from Istanbul.
⚡ Short Answer
A UAE court judgment cannot be enforced in Türkiye automatically; under MÖHUK Art. 50 et seq., an enforcement or recognition decision must be obtained from a Turkish court. The reverse also requires a separate enforcement application in the UAE. For divorce, inheritance, labour and cheque disputes, jurisdiction and applicable law are determined on the facts. Maya Avukatlık Bürosu serves clients from Istanbul (Kartal); it has no office in the UAE and cooperates with UAE law firms where needed.
Contents
Why Get Support from Istanbul for UAE-Related Matters in Türkiye?
Maya Avukatlık Bürosu (Maya Law Office) serves clients from Kartal, on the Anatolian side of Istanbul. We handle litigation, enforcement, land registry, family and commercial matters in Türkiye for foreign nationals and for people living abroad.
We do not have an office in the UAE. Where UAE law requires a step to be taken there, we cooperate with locally licensed UAE law firms depending on the nature of the file. The Turkish side of the process is managed from Istanbul. This division is made clear at the start of every file.
- Handling enforcement, recognition, debt and family cases in Türkiye
- Preliminary assessment of UAE judgments and documents for use in Türkiye
- Coordination with a UAE firm where steps must be taken in the UAE
- Planning sworn translation and legalisation steps
How Does the UAE Legal System Differ from Turkish Law?
The UAE is a federation of seven emirates. In addition to federal legislation, courts and rules operate at emirate level. Free zones such as the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) have their own legal and court systems.
Personal status is also separate. For non-Muslims, Federal Decree-Law 41/2022 has applied since 1 February 2023; it allows no-fault divorce and lets parties request the application of their home-country law. Abu Dhabi has its own Law 14/2021. Muslim parties remain subject to separate personal status legislation.
Which Country's Court?
Courts in both countries may have jurisdiction over the same event. Before filing, jurisdiction, applicable law and the country where the judgment will be enforced should be assessed together.
How Is a UAE Court Judgment Enforced in Türkiye?
A UAE court judgment cannot be enforced in Türkiye automatically. To make it enforceable, an enforcement (exequatur) action is filed; to have its legal effects acknowledged, a recognition action is filed. Both are governed by Articles 50–59 of Law No. 5718 on Private International and Procedural Law (MÖHUK).
Legal Basis
MÖHUK Arts. 50–59: enforcement and recognition. Art. 51: competent court (court of first instance for civil matters). Art. 52: enforcement petition. Art. 54: conditions. Art. 58: recognition.
Core Requirements
- The judgment must be final
- Reciprocity must exist (it may rest on a statute, a treaty or de facto practice)
- The matter must not fall within the exclusive jurisdiction of Turkish courts
- The judgment must not be manifestly contrary to Turkish public order
- The right of defence must have been respected (proper summons)
Documents Usually Required
- A certified copy of the judgment and a finality certificate
- Documents proving service and summons
- Sworn translation and required legalisation
⚠️ Important Point: Status of the Bilateral Treaties
On 19 July 2023, Türkiye and the UAE signed treaties on mutual legal assistance in civil and commercial matters (including recognition and enforcement), mutual legal assistance in criminal matters, and extradition. They were sent to the Turkish Grand National Assembly, and its Foreign Affairs Committee adopted the civil and commercial treaty in 2025; the UAE's internal approval process was reported as ongoing. Their in-force status must be confirmed on the date of filing. If they are not in force, reciprocity is examined separately under MÖHUK Art. 54.
How Is a Turkish Judgment Enforced in the UAE?
In the UAE, foreign judgments and arbitral awards are enforced through an application to the Execution Judge under Articles 222–225 of Federal Decree-Law 42/2022 (Civil Procedure). The court examines finality, the jurisdiction of the foreign court, public order and reciprocity. Under Article 225, treaty provisions take priority where they exist.
DIFC and ADGM courts operate under a separate regime, and enforcement in those zones follows separate mechanisms.
The UAE application is filed by UAE-licensed lawyers. At this stage we coordinate with the UAE firm and prepare the Turkish side (finality certificate, translations, document set). Arabic translation and legalisation requirements are determined with the UAE firm.
Are UAE Divorce and Custody Decisions Valid in Türkiye?
A UAE divorce judgment is not automatically registered in Turkish civil records; a recognition decision must be obtained first (MÖHUK Art. 58). Where alimony, custody or property provisions require enforcement, an enforcement action may also be needed.
Custody, contact rights and the child's country of residence call for a separate assessment. The country that issued the decision, the child's habitual residence and the parties' nationalities shape the outcome.
⚠️ Important Point: Child Abduction
Türkiye has been a party to the 1980 Hague Child Abduction Convention since 1 August 2000. The UAE is not a party. If a child is taken to or from the UAE, the Convention's return mechanism therefore does not operate between the two countries, and local courts and diplomatic channels become relevant. Action should be planned without delay.
Inheritance After a Death in the UAE and the Certificate of Inheritance
As a rule, succession is governed by the deceased's national law; for immovable property in Türkiye, Turkish law applies (MÖHUK Art. 20). For assets in Türkiye, the first step is often obtaining a certificate of inheritance (Turkish Civil Code Art. 598).
Bank accounts, real estate and company shares in the UAE require a separate procedure there. The procedure may differ depending on the deceased's religion and nationality. We coordinate with the UAE firm at this stage.
If Assets Are in Both Countries
The applicable law depends on the deceased's nationality and where the assets are located. Assets in two countries usually require two separate procedures.
End-of-Service Gratuity and Other Labour Claims After Working in the UAE
Employment in the UAE is governed by Federal Decree-Law 33/2021. End-of-service gratuity is calculated at 21 days' wages per year for the first five years and 30 days' wages per year thereafter, and is payable within 14 days of the end of the employment relationship.
In a dispute, the Ministry of Human Resources and Emiratisation (MOHRE) mediation stage comes first. Since 1 January 2024, MOHRE can decide claims under AED 50,000; if no settlement is reached or the amount is higher, the matter goes to court.
For work performed in Türkiye, mandatory mediation and the labour court route apply.
⚠️ Important Point: Time Limits
Limitation periods for UAE labour claims are short (generally two years). The date on which time starts to run is assessed on the facts of each file, so a legal review should be made as soon as documents are collected.
UAE Cheque and Debt Disputes: Travel Bans and Debt Recovery
Under Federal Decree-Law 50/2022 (Commercial Transactions), bounced cheques have in principle been decriminalised in the UAE since 2 January 2022, and the cheque is treated as an executive instrument. Exceptions in which criminal liability remains are reserved. Measures such as travel bans may be imposed in connection with debts.
If you are a creditor in the UAE and the debtor has assets in Türkiye, two routes are considered: enforcing the UAE judgment in Türkiye, or, where jurisdiction exists, suing and enforcing directly in Türkiye. The choice depends on the documents and jurisdiction.
Anyone who believes a debt or enforcement file exists against them in the UAE should have this checked through a UAE-licensed lawyer before acting.
Companies, Investment and Arbitration in the UAE: What to Watch
On the UAE mainland, foreign ownership of up to 100% is possible outside activities with strategic impact (Federal Decree-Law 32/2021, as amended by Federal Decree-Law 20/2025). Free zones follow their own rules.
The Türkiye–UAE Comprehensive Economic Partnership Agreement (CEPA) was signed on 3 March 2023 and entered into force on 1 September 2023. CEPA is a trade and investment framework; it is not a treaty regulating the enforcement of court judgments.
Choosing the competent court or arbitration clause in a contract affects where a future decision can be enforced. The UAE applies Federal Law 6/2018 on arbitration. The UAE acceded to the New York Convention on 21 August 2006, and Türkiye is also a party.
UAE Property, Powers of Attorney and Document Formalities
In the UAE, foreigners can hold freehold property only in designated areas (for example, Abu Dhabi Law 19/2005, as amended by Law 13/2019, and designated freehold areas in Dubai). In Türkiye, property acquisition by foreigners is subject to the restrictions in Article 35 of the Land Registry Law.
For UAE powers of attorney, judgments and commercial documents to be used in Türkiye, the legalisation and sworn translation requirements depend on the type of document and the issuing authority. This procedure is confirmed against current rules before any step is taken.
How to Send Your File: Our Working Process
Our Service Areas for UAE-Related Matters
17 Common UAE-Related Issues
1. Enforcement of a UAE Judgment
Judgments that require execution need an enforcement action in Türkiye, with a review of reciprocity and public order.
2. Recognition of a UAE Divorce
A recognition decision is needed before the divorce can be registered in Turkish civil records.
3. Property Division
Applicable law and the location of assets are assessed together when dividing marital property.
4. Custody and Contact Rights
The effect in Türkiye of UAE custody decisions depends on the nature of the decision and the child's residence.
5. Taking a Child Abroad
The UAE is not a party to the Hague Child Abduction Convention, so the Convention route does not apply; action should be planned without delay.
6. Certificate of Inheritance
For assets in Türkiye, the first step is often a certificate of inheritance (Turkish Civil Code Art. 598).
7. UAE Bank Accounts and Assets
Accounts and property in the UAE require a separate UAE procedure and coordination with a UAE firm.
8. End-of-Service Gratuity
For those who worked in the UAE, the MOHRE stage comes first, followed by court proceedings if needed.
9. Wages and Other Labour Claims
Time limits and documents for unpaid wages and similar claims should be reviewed early.
10. Cheque and Promissory Claims
A UAE cheque may be treated as an executive instrument; the debtor's assets in Türkiye are examined separately.
11. Travel Bans and Enforcement
If a travel ban or enforcement file is suspected in the UAE, it should be checked through a UAE-licensed lawyer.
12. Company Formation and Partner Disputes
Mainland and free-zone companies are governed by different regimes; jurisdiction and governing-law clauses matter.
13. Commercial Contracts and Arbitration Clauses
The jurisdiction or arbitration clause decides in which country a dispute is resolved.
14. Enforcement of Arbitral Awards
Both the UAE and Türkiye are parties to the New York Convention, so awards are assessed under it.
15. Property Purchase and Title
Foreign freehold in the UAE is limited to designated areas; in Türkiye, foreign acquisition is subject to Land Registry Law Art. 35.
16. Powers of Attorney
Legalisation and translation requirements for a UAE power of attorney should be clarified before use in Türkiye.
17. Sworn Translation and Legalisation
The translation and legalisation chain for judgments, civil records and commercial documents should be planned from the start.
Frequently Asked Questions
Is a UAE court judgment automatically valid in Türkiye?
No. An enforcement action is needed to execute it, and a recognition decision to have its legal effects acknowledged (MÖHUK Art. 50 et seq.).
Is there a treaty between Türkiye and the UAE on recognising court judgments?
Treaties were signed in 2023; their in-force status must be confirmed on the date of filing. If they are not in force, reciprocity is examined separately under MÖHUK Art. 54.
How is a UAE divorce judgment made valid in Türkiye?
A recognition decision is obtained first; the judgment is then registered in the civil records.
How can someone who worked in the UAE claim end-of-service gratuity?
MOHRE mediation comes first in UAE labour disputes; if no settlement is reached, the matter goes to court. Because limitation periods can be short, apply without delay.
Do you have an office in the UAE?
No. We serve from Kartal, Istanbul. For steps that must be taken in the UAE, we cooperate with UAE law firms where needed.
How can I send my file?
You can send your documents through our contact page; a preliminary review is carried out for your file.
✅ Conclusion: What Should You Do?
If you have a judgment, document or dispute connected with the UAE, send your documents to Maya Avukatlık Bürosu through our contact page before time limits pass. A preliminary review is carried out and the steps in Türkiye and the UAE are separated.
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