Succession Upon Death: A Comparison of European and Turkish Private International Law

Born 1987; legal studies at Istanbul University; LL.M. (Queen Mary University London); 2021 PhD (University of Regensburg); since 2020 Senior Research Fellow and Head of the Centre of Expertise on Turkey at the Max Planck Institute for Comparative and International Private Law, Hamburg.

• Chapter 1: General Overview and BackgroundTurkish-EU SuccessionsBackground of the Regulation and Its Four PillarsBackground of Turkish Private International Law on Succession and a General Overview of Its RulesBackground of the Turkish-German Treaty and a General Overview of Its Rules as well as Its Scope of ApplicationConcluding Remarks as to General Overview and BackgroundChapter 2: Conflict of Laws in Turkish-EU SuccessionsMonist vs. Dualist ApproachDifferent Connecting Factors: Last Habitual Residence vs. Lex Patriae + Lex Fori/Lex Rei SitaeProfessio Iuris?The Scope of the Applicable LawsThe Law Applicable to Dispositions of Property upon DeathOther Issues Related to the Law Applicable to SuccessionConcluding Remarks as regards the Conflict of Laws in Turkish-EU SuccessionsChapter 3: Procedural Issues in Turkish-Eu SuccessionsJurisdictionProcedural Issues in Relation to The European Certificate of SuccessionConcluding Remarks on Procedural IssuesConclusion