Cross-Border
Legal Counsel in Turkey

Turkey is a civil-law jurisdiction whose private law draws heavily on Continental European models, with codified civil, commercial, and procedural law. Disputes are decided by professional judges across a structure of first-instance courts, regional courts of appeal, and the Court of Cassation (Yargıtay) for civil and commercial matters. Turkey also has specialised commercial courts handling business disputes.
For foreign parties, the relevant features are the civil-law procedural framework, the existence of specialised commercial courts, and Turkey's developed arbitration regime. Turkish procedure is document-driven and conducted by judges. As with many civil-law jurisdictions, the length of ordinary litigation and the consequent value of arbitration and interim measures are practical considerations.
Turkey's regulatory environment and its rules on foreign investment can affect transactions, and its position bridging multiple regions means cross-border matters frequently involve coordinating Turkish requirements with those of neighbouring markets.
Foreign parties should also be aware of the practical importance of Turkey's specialised commercial courts and the role of mandatory mediation as a procedural gateway for certain commercial disputes before litigation can proceed. Understanding where mediation is a precondition, and how to use it strategically rather than treating it as a formality, can affect both the timeline and the leverage in a Turkish commercial dispute.

Turkey is a party to the New York Convention, and Turkish courts recognise and enforce foreign arbitral awards under its framework, applying the Convention's narrow refusal grounds. Turkey's arbitration regime has developed to support both domestic and international arbitration, and an arbitral award is generally a sound basis for enforcement against Turkish assets.
For foreign court judgments, Turkey applies its own recognition and enforcement procedure (tenfiz), examining matters such as reciprocity, proper service, and consistency with Turkish public policy. The reciprocity requirement makes the relationship between Turkey and the originating jurisdiction relevant, and the procedure must be navigated carefully.
The practical work is choosing the enforceable route — frequently arbitration for the certainty of New York Convention enforcement — navigating the relevant Turkish recognition procedure, and then enforcing against Turkish assets with attention to asset identification and procedural realities. We coordinate the Turkish enforcement with any parallel action elsewhere.
A point specific to Turkish enforcement is the reciprocity requirement in the tenfiz procedure for foreign judgments, which makes the treaty and de facto relationship between Turkey and the originating jurisdiction a threshold question. Because reciprocity can be uncertain, the certainty of New York Convention award enforcement is often decisive in steering parties toward arbitration when they structure their contracts — a choice that pays off precisely at the enforcement stage.

The Istanbul Arbitration Centre (ISTAC) is Turkey's principal arbitral institution, established to position Istanbul as a regional centre for international arbitration, and Turkish courts apply the New York Convention to foreign awards. ICC and other institutional proceedings involving Turkish parties are also common, with seats chosen according to the matter.
For a foreign party, the choice of seat and institution for a Turkey-related dispute turns on enforceability, neutrality, and the regional context — Istanbul as a regional centre, or a neutral European or Gulf seat depending on the counterparties. We advise on the choice with enforcement against the relevant assets in mind.
Istanbul's position bridging Europe, the Middle East, and Central Asia gives ISTAC a natural constituency for disputes among parties from those regions seeking a neutral seat closer than the traditional European centres. For a foreign party, the choice between Istanbul, a European seat, and a Gulf seat turns on neutrality, the location of assets, and the regional comfort of the counterparties — a calculation we make with enforcement as the anchor.
The growth of ISTAC reflects a broader Turkish ambition to retain and attract dispute resolution that might otherwise default to European or Gulf centres, and for parties comfortable with a regional seat it offers proximity and cost advantages. For others, particularly where the counterparties are split across regions, a neutral European or Gulf seat may better serve enforceability and perceived neutrality — a calculation we make on the specifics of the matter and the location of the assets ultimately at stake.

Turkish matters that reach us reflect the country's role as a trade and investment bridge. Trade, construction, and supply disputes are a significant cluster, given Turkey's large construction and contracting sector operating across the region and its position in international trade routes. Investment and joint-venture disputes involving Turkish and foreign parties are a second cluster.
A third is enforcement and recovery against Turkish assets, where the choice between the New York Convention route and the tenfiz judgment-recognition procedure shapes strategy. Across these, the recurring theme is Turkey's role connecting Europe, the Middle East, and Central Asia, and the consequent multi-regional character of the disputes.
We do not handle Turkish domestic litigation unconnected to a cross-border dimension, routine regulatory filing, or consumer matters. Our work is the Turkey-connected cross-border dispute or transaction that benefits from regional experience and enforcement-focused structuring.
Turkish matters concentrate in construction and contracting (where Turkish firms are major international players across the Middle East, Africa, and Central Asia), energy, manufacturing and textiles, and trade. The international construction sector is especially prominent: Turkish contractors operating across the region generate FIDIC-based and other construction disputes that frequently proceed by arbitration with cross-border enforcement dimensions.

Turkish matters are run on our standard coordination model, with the Middle East & Asia desk providing experience across the region Turkey bridges. Turkish local counsel are engaged and coordinated where local qualification and court appearances require it, under the VLO partner who owns the overall strategy.
Coordination matters in Turkish matters because they so frequently span multiple regions — a Turkish party with European, Gulf, and Central Asian connections — and because enforceability often depends on structural choices made upstream. One partner coordinating the Turkish element with proceedings and assets across the connected markets is how these multi-regional matters are kept coherent.

Turkey rewards enforcement-focused forum choice and attention to the reciprocity requirements of judgment recognition. We scope the Turkish issues alongside every other jurisdiction in play, deliver a strategy memo with a procedural map and fee structure within five business days, run the Turkish matter through our Middle East & Asia desk with local counsel, and report to you in English.

Turkey rewards counsel who understand its position as a bridge between Europe, the Middle East, and Central Asia, and who approach enforcement with the right structural choices in mind — frequently arbitration, for the certainty of New York Convention enforcement, over reliance on the reciprocity-dependent judgment-recognition procedure. Its developed but still-maturing arbitration regime, and the multi-regional character of its disputes, reward regional experience.
VLO's value in Turkey is a partner experienced across the region Turkey connects, who structures Turkish dispute-resolution mechanisms for enforceability and coordinates the Turkish element with the European, Gulf, or Central Asian sides of a matter — working with Turkish counsel where local qualification is required.
For clients trading with or investing through Turkey, this means a dispute strategy built for enforceability and aware of the regional context, run by one partner who coordinates the whole multi-regional picture, with the discretion sensitive commercial matters require.