LEGAL ASSESSMENT

The country where the claim is located and the country where it is collected may differ

International debt collection is the pursuit, by legal means, of claims in which the debtor, the contract or the assets suitable for collection are connected with different countries. Winning the case does not mean that the claim has actually been collected. The competent authority, the applicable law, the evidence and the debtor’s accessible assets are assessed together at the outset.

Güneş & Güneş Law Firm carries out advisory, litigation and follow-up work in Türkiye for export payments, service invoices, commercial accounts, contract claims and claims based on a foreign decision. Work and representation abroad are coordinated with an attorney authorized in the relevant country, within a separately determined mandate and fee.

SCOPE OF SERVICES

Our Attorney Services for Cross-Border Claims

Review the heading that fits your needs. The work to be undertaken is determined by assessing the documents and the circumstances of the file.

Review of the claim and the prospects of collection

The basis of the claim, the debtor’s actual identity and the economic traceability of the transaction are assessed.

Comparison of contract, order, invoice, delivery and payment records
Distinguishing between the debtor company, its representative, the surety and the guarantor
Planning an inquiry into assets and ability to pay from lawful sources

Export and service payments

The dispute between the performance of the goods or services and the payment obligation is identified on the basis of concrete records.

Assessment of delivery, transport, acceptance and defect notices
Review of letters of credit, guarantees and payment terms
Reflecting the current account, set-off and partial payments in the calculation of the claim

Negotiation and payment protocol

The contribution of an out-of-court solution to collection is considered together with the risks relating to time and security.

Preparing the legal basis of the formal notice (ihtar) and the payment demand
Drafting the provisions on instalments, maturity dates, security, acceleration and breach
Linking waiver and release wording to the actual conditions of payment

Litigation and enforcement proceedings in Türkiye

If jurisdiction and the conditions for enforcement proceedings exist in Türkiye, the route suited to the nature of the claim is determined.

Assessment of the options for enforcement with a judgment, enforcement without a judgment and document-specific enforcement
Following up on the debtor’s objection, the action on the claim and the related application routes
Initial check of mediation as a condition precedent to litigation and of the arbitration clause

Enforcement of foreign decisions

The conditions required for a foreign court judgment or arbitral award to be applied in Türkiye are examined.

Checking the decision and the documents on finality or binding effect and on notification
Distinguishing the regime applicable to court judgments from that applicable to arbitral awards
After the enforcement decision, follow-up and collection steps before the competent enforcement office

Coordination of follow-up abroad

Steps in the country where the debtor or the assets are located are planned through locally authorized counsel.

Checking conflicts of interest, professional authority and the scope of the engagement
Researching the conditions for applying a Turkish decision in the relevant country
Determining the arrangements for local expenses, translation, documents and reporting

Precautionary attachment and interim protection

Interim protection that may be applied against the risk of the assets being disposed of is assessed.

Examination of the nature of the claim, its maturity, the evidence and the security requirements
Taking into account that an interim measure in Türkiye is not applied abroad automatically
Monitoring the time limits for implementation and complementary steps after the decision

Bankruptcy and restructuring

The debtor’s payment difficulties may call for a different process in place of, or alongside, individual enforcement.

Registration of the claim in bankruptcy, composition with creditors (konkordato) or foreign liquidation proceedings
Assessment of secured claims, priority and the likelihood of distribution
Lawful application options regarding dispositions and suspicious transfers

Implementation of collection and closing

The closing of the file is arranged by checking the payment, the enforcement costs and the remaining debt together.

Reconciling the principal, interest, currency and payment date
Examining bank-related and sanctions-related obstacles to payment with the relevant specialists
Notice of collection, release of security and an arrangement for limited release

BEFORE YOU DECIDE

Legal Distinctions That Determine the Route of Pursuit

Whether a lawsuit can be filed in a country, whether assets are located in that same country and whether a decision can be applied directly in another country are separate matters.

Court with jurisdiction and applicable law

A choice of law in the contract and a choice of court or arbitration produce different results. In Türkiye, international jurisdiction is assessed through the domestic rules on territorial jurisdiction, subject to the relevant special rules and agreements. A contract choosing a Turkish court is not required in every case in order to file a lawsuit in Türkiye.

Recognition, enforcement and actual collection

Recognition concerns the res judicata or conclusive-evidence effect of a foreign court judgment; enforcement concerns its enforceability. For the execution of a foreign court judgment in Türkiye, the applicable agreements and the provisions of MÖHUK are examined. After an enforcement decision, attachable assets and enforcement steps are additionally required.

A foreign creditor’s security

For foreign individuals and legal entities that file a lawsuit or conduct enforcement proceedings in Türkiye, the security under MÖHUK Article 48 and the exemptions that may arise from reciprocity and international agreements are checked. This review is separate from the security that may be requested for interim protection.

Time limits and the effect of negotiations

The statute of limitations and the time limits for objecting to enforcement proceedings, for filing a lawsuit and for registering a claim are not a single time limit. The law applicable to the contract and the transaction and the date of notification are determined. Holding payment discussions or sending a formal notice does not automatically suspend all time limits in every legal system.

Territorial authority of enforcement bodies

It cannot be assumed that an act of a Turkish enforcement office places an attachment directly on a bank account in a foreign country. The target country’s rules on recognition, enforcement, interim protection and local representation are examined separately. Procedures within the European Union are also not applied automatically to every dispute with a Türkiye connection.

Company debt and personal liability

A company manager, a shareholder or another company in the same group is not regarded as the debtor of every commercial debt solely because of that status. The conditions of suretyship, guarantee, assumption of debt, tort or special liability, and the applicable law, are assessed in the specific case.

OUR APPROACH

Our Approach to Collection in a Claim File

We do not regard the file as consisting merely of an unpaid invoice. We examine together how the amount claimed will be proved through the contract, delivery, acceptance, objection and payment records, and which assets can be reached in which country. In the first assessment, the expected costs, the time-related risks and the limits of the information available are explained alongside the legal route.

Identifying the debt and the country connections
A map of the file is drawn up on the basis of the creditor and debtor details, the contract, the maturity date, the currency, the record of the dispute and the known assets.
Preparing the evidence and pursuit plan
Missing documents, jurisdiction, the applicable law, the mediation or arbitration requirement and the need for interim protection are identified. If steps abroad are required, the engagement of local counsel is planned separately.
Conducting negotiation or the legal application
After acceptance of the matter and the necessary authorization, the appropriate formal notice, negotiation, lawsuit, enforcement of a foreign decision or follow-up step is carried out. Applications subject to time limits are monitored independently of payment discussions.
Implementing the decision and monitoring collection
Objections, asset-related steps, local expenses and the amounts collected are monitored. Significant developments in the file are explained to the client.
Clarifying the account and closing
The amount paid and the amount remaining, fees and expenses, the security to be released and the claims that will continue are determined separately.

PREPARING FOR THE FIRST CONSULTATION

Information and Documents for an International Claim File

A short summary of the matter is enough for the first inquiry. Detailed documents are requested through a secure channel once the scope of the review has been determined.

What you can prepare at the start

Name, country and known current address of the creditor and the debtor
Contract or order, and the amount of the claim, currency and maturity date
Invoice, delivery or service performance records and a statement of payments
The debtor’s objections, payment offers and important correspondence
Existing lawsuit, enforcement proceeding, decision or the date of an upcoming step

What may be requested depending on the file

Registry or authority documents on signatures and on the power to represent the company
Documents on guarantee, suretyship, pledge, letter of credit and security
Court or arbitral decision, finality/binding effect and notification records
Lawfully obtained records on known assets
Powers of attorney, translations and document certifications required by the target country

Certification of a foreign document and its legal effect are different things

An apostille or consular certification relates to the verification of the official elements concerning the issuance of the document; it does not by itself establish the existence of the debt, authority or the enforceability of the decision in Türkiye. The certification exemption under the relevant agreement and the nature of the document to be used are checked separately.

Confidentiality of your information

The information and documents you share are used, within the framework of the attorney’s professional secrecy and the principles of personal data protection, only for legal assessment and for carrying out the work undertaken. Do not send passwords, access codes or unnecessary identity information. For sensitive documents, use the secure sharing method that our office will specify.

Statement on confidentiality and information security

REPRESENTATION AND COMMUNICATION

Antalya-Based Follow-Up of Claims Connected With Türkiye and Abroad

Güneş & Güneş Law Firm, founded in Kemer on March 18, 1999 and based in Antalya since 2007, undertakes work on claims, the enforcement of foreign decisions and follow-up before the competent courts and enforcement offices throughout Türkiye, depending on the circumstances of the file. The document arrangements of export, tourism, logistics, production and cross-border service relationships are included in the review of the claim.

Communication in Turkish, English, German and Russian supports the handling of foreign documents and the briefing of the client. Professional representation in a foreign country is carried out by an attorney authorized in that country; our office’s coordination role, document flow and responsibility are determined separately.

Distinguishing fees from expenses

The attorney’s fee and, if any, the coordination fee are explained together with their scope, separately from court/enforcement costs, translation, certification, security, asset inquiry and the fee of a foreign attorney. Collection or any specific outcome is not guaranteed.

Authority and sharing of documents

Legal representation is based on the necessary power of attorney and the acceptance of the matter. The scope of the information and documents to be shared with foreign counsel, the secure transfer method and the relevant data protection obligations are determined.

Information and monitoring of time limits

Information is given about important steps, decisions taken, collection and the client decisions that are needed. In a file that has not yet been accepted, merely submitting an inquiry does not begin the monitoring of time limits.

FREQUENTLY ASKED QUESTIONS

Questions About International Debt Collection

The answers are general information. The route and conditions that apply to your request are assessed on the basis of specific information and documents.

If the debtor is abroad, can the claim be pursued in Türkiye?

The debtor’s being in a foreign country does not by itself close all Turkish application routes. The jurisdiction of Turkish courts and enforcement bodies, the basis of the claim, the contract provisions and the assets in Türkiye are examined together.

Is collection possible with an invoice alone?

Alongside the invoice, the order, contract, delivery, acceptance, objection and payment records are important. Which document is suitable for which enforcement or litigation route is determined according to the applicable law and the dispute.

Can I apply directly to a shareholder of the debtor company?

The liability of the company and that of the shareholder or manager are assessed separately. A company debt is not accepted as a personal debt without a valid personal security or a special ground of liability.

If I have a foreign court judgment, is a new claim action filed?

Depending on the nature of the decision, the route of recognition or enforcement may come into question. In Türkiye, enforcement is, as a rule, not a re-examination of the merits of the dispute; it is an examination of the conditions in the relevant law and agreement.

Do the same rules apply to a foreign arbitral award?

No. For arbitral awards, the applicable international conventions, Türkiye’s reservations and the relevant provisions of MÖHUK are assessed separately. Not all the conditions that apply to a court judgment are carried over as they are.

Is your access to the debtor’s assets unlimited?

No. The inquiry is limited to accessible official records and the lawful actions of the competent authorities. No unauthorized access is obtained to bank accounts, private data or foreign registry records.

Should the pursuit be abandoned once a payment protocol is signed?

This decision is assessed together with whether payment is actually made and with the security. Because an early release or waiver can lead to a loss of rights as regards the unpaid balance and the existing safeguards, the effect of the protocol should be determined in advance.

Can the claim be demanded in a foreign currency?

The currency, the exchange rate date and the interest claim are set according to the contract, the applicable law and the route of pursuit. It is not assumed that the same amount can be claimed in every country at the same exchange rate and interest.

Is pre-litigation mediation mandatory for every claim?

No. In Türkiye, mediation as a condition precedent to litigation is checked on the basis of the type of dispute and the statutory scope. Initiating enforcement proceedings, filing a claim action and arbitration are distinguished from one another.

If the debtor has gone bankrupt, does my claim come to an end?

Bankruptcy does not mean that the claim has been paid automatically or that it comes to an end in every case. The registration of the claim in the relevant country, the ranking, the security and distribution conditions, and the time limits are examined.

Can the file be handled without coming to Türkiye?

Many document reviews and follow-up steps can be carried out with an appropriate power of attorney. If a step requires personal attendance or a different authorization, this is notified separately.

Are the duration and cost of collection fixed in advance?

The country, notification, the debtor’s objection, legal remedies, assets and payment difficulties affect the duration. The scope and the expense items can be explained at the outset; a definite collection date or a promise of an outcome cannot be given.

RELATED SERVICES AND LEGAL BASIS

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Official legal sources

The sources used in preparing this text were reviewed on October 4, 2026. A review of sources does not replace a legal opinion tailored to the individual.

NEXT STEP

Let’s Determine the Basis of Your Claim and the Route of Pursuit

Please share your request, a short summary of the facts and, if any, the date of an upcoming step. At the first consultation, which documents will be reviewed and which legal routes will be considered is clarified.

Subject of the inquiry: International Debt Collection and Cross-Border Enforcement

Request a Consultation About a Claim Request an Appointment

First response: within 48 hours at the latest. This period is not the time in which the legal review is completed or the matter is concluded.

Submitting an inquiry does not mean that an attorney–client relationship has been established or that monitoring of the file and its time limits has been taken on. The consultation fee is communicated in advance.

International Debt Collection and Cross-Border Enforcement