This study examines inheritance relationships and inheritance contracts involving foreign elements within the legal frameworks of Uzbekistan and Türkiye. The rise of international migration and transnational economic activities has increasingly brought foreign elements to the forefront of inheritance law. The presence of assets connected to multiple states, differences in the deceased’s nationality or last residence, and heirs’ foreign status create significant legal challenges in determining the applicable law. The study analyzes cross-border inheritance relations under the legislation of Uzbekistan and Türkiye. Under Uzbek law, modern civil law reforms have introduced inheritance contracts as alternatives to wills, providing mutually agreed arrangements that enhance legal certainty and protect heirs’ rights. In Turkish law, the law applicable to inheritance relations involving foreign elements is determined by the Law on International Private and Procedural Law No. 5718; Turkish law applies to immovable property, and inheritance contracts are executed in accordance with the reserved portion regime. The study demonstrates that the adoption of inheritance contracts in national legislation serves as an important tool for promoting stability, predictability, and the reduction of disputes in inheritance law practice.
| Mualliflar | Erol, Maralgul, Khalbekova, Nilyufer, Zakhidova, Nozima, Эрол, Маралгүл, Халбекова, Нилюфер, Захидова, Нозима, Erol, Maralgul, Xalbekova, Nilufer, Zaxidova, Nozima |
|---|---|
| Jurnal | Жамият ва инновациялар / Общество и инновации / Society and innovations |
| Nashr sanasi | 2026-02-05 |
| Jild | 7 |
| Son | 1 |
| Betlar | 212-221 |
| Til | Rus |
| DOI | 10.47689/2181-1415-vol7-iss1-pp212-221 |
DOI: 10.47689/2181-1415-vol7-iss1-pp212-221 · Maqolaning asl sahifasi
наследственное право, иностранный элемент, Гражданский кодекс Узбекистана, частное международное право, Гражданский кодекс Турции, Inheritance Law, Foreign Elements, Uzbek Civil Code, International Private Law, Turkish Civil Code, meros huquqi, xorijiy element, Oʻzbekiston Fuqarolik kodeksi, xalqaro xususiy huquq, Turkiya Fuqarolik kodeksi
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