Cубъекты наследования по закону в Республике Казахстан и в Турецкой Республике: компаративистский анализ

In the context of actively developing relations between the Republic of Kazakhstan and the Republic of Turkey, the issues of regulating the legal status of subjects of inheritance by law are becoming especially relevant. Due to the peculiarities of national, historical, religious, cultural and family traditions, inheritance relations complicated by a foreign element are among the most difficult in legal regulation. According to the authors, the study and analysis of the legal status of subjects of inheritance by law seems so significant, since due to active migration processes between the two countries, many citizens of Kazakhstan and Turkey have relatives in these countries, and accordingly inherit after them under the legislation of another state. A comparative legal analysis of the current inheritance legislation in the field of regulation of the legal status of inheritance under the legislation of the Republic of Kazakhstan and the Republic of Turkey showed significant differences in the legislative regulation of subjects of inheritance under the legislation of the two countries. Based on the comparative legal analysis of the current legislation of the Republic of Kazakhstan and the Republic of Turkey, a number of differences were identified in the order of priority, the spouse's share in the inherited property and the taxation policy of the inherited property. At the same time, there are also common approaches to determining the inheritance status and to determining the status of the testator. In practical terms, this study is of interest to lawyers practicing in the field of inheritance law, as well as international private law. Keywords: inheritance law, subjects of inheritance, legal status of subjects of inheritance by law, inheritance legal relationship complicated by a foreign element, testator, heir, unworthy heirs, tax on inherited property, ownerless property.