In the first seven months of 2026, Turkey’s exports to member countries of the Organisation of Islamic Cooperation reached USD 41.5 billion. A Turkish company doing business in the Middle East that relies solely on a lawyer versed in Turkish law can run into serious gaps in contracting, collections, and licensing. The reason is straightforward. Each country’s commercial, corporate, and enforcement law is shaped by its own legislation, court practice, and in some cases local commercial custom, and that divergence creates risks a Turkish lawyer cannot foresee alone.
Why Turkish Companies Are Moving Into the Middle East Faster
Picture a mid-sized textile exporter in Istanbul. Having sold into Europe for years, the company notices rising demand from Gulf markets and starts talks with distributors in Qatar and the United Arab Emirates. This scenario is no longer the exception; it is a natural consequence of the region’s economic momentum.
According to Ministry of Trade data, the regional recovery is uneven but picking up pace. In August 2026, manufacturing output growth in the UAE hit its fastest pace in six months, and in Saudi Arabia its fastest in seven. At the same time, annual export growth to OIC member states was limited to USD 345.7 million, meaning the growth opportunity exists but is not automatic. As companies move quickly to seize it, legal preparation is often pushed to second place.
The Risk of Relying on a Single Legal System
Suppose the textile company above had its contract with the Qatari distributor reviewed only by its Turkish legal advisor. Even if the agreement looks flawless under Turkish law, agency and distributorship relationships, corporate law, and in some cases local commercial custom can work differently in Qatar.
Across the Gulf states, company formation, permitted foreign ownership ratios, licensing, and capital requirements vary from country to country, and sometimes from one free zone to another within the same country. Citing a specific article number or percentage here would be misleading, since regulations are updated frequently and a general blog post cannot substitute for that country’s official source. The right approach is to identify the risk area and obtain concrete confirmation from a local law firm in that jurisdiction.
How Turkish Law Frames Contract and Arbitration Security
So on what legal basis can the Turkish party secure this relationship? Under Turkish law, the recognition and enforcement of foreign court judgments and arbitral awards is governed by Law No. 5718 on Private International Law and Procedural Law, which entered into force on 12 December 2007. Where foreign arbitral awards are concerned, the 1958 New York Convention also applies.
Consider a company that includes an arbitration clause in its contract with a partner in Dubai but never asks how an award would be enforced in Turkey if the counterparty fails to pay. Enforcement first requires the existence of a valid arbitration agreement and satisfaction of the reciprocity requirement. This is why, when drafting commercial contracts, settling the choice of jurisdiction and arbitration forum from the outset prevents enforcement disputes down the line. The points we previously covered on drafting and reviewing commercial contracts become even more critical in cross-border transactions.
Why Local Support Matters for Debt Collection
Imagine a Turkish company selling construction materials in Iraq whose local partner delays payment by six months. An enforcement order obtained in Turkey does not automatically apply against assets located in Iraq. Actually collecting the debt generally requires local legal support familiar with that country’s enforcement and court procedures.
This turns enforcement and debt collection into an issue that must be planned before the contract is signed, not after. Tools such as a letter of guarantee, an advance payment ratio, or a collection mechanism registered with the local regulator should be assessed at the contract-drafting stage. While experience with debt recovery through enforcement proceedings in Turkey is a useful reference point, enforcement abroad requires support on enforcement and debt collection from someone who knows that country’s own procedure.
Building a Coordination Model With a Local Law Firm
Suppose a Turkish company wants to open a branch in a UAE free zone and must manage licensing, lease agreements, and work permits all at once. In a process like this, having the Turkey-based legal advisor and the local law firm work in parallel ensures that the contract complies with Turkish corporate law while local licensing requirements are met at the same time.
Under this model, the Turkey-based advisor tracks the master agreement, the ownership structure, and Turkey-side tax and reporting obligations, while the local law firm handles that country’s current regulations, licensing, and registration procedures. If the two sides do not share information, the same transaction can end up structured incorrectly on both ends. Running the process through a single coordination point is therefore the most practical way to keep it consistent.
Conclusion: Building Legal Readiness From the Start
For a Turkish company looking to grow in the Middle East, legal risk management is something to plan before entering the market, not after. The sequence below offers a practical framework.
- Before signing any contract, clarify which country’s law and which arbitration or court forum will govern the relationship between the parties.
- Confirm local corporate law, licensing, and foreign ownership requirements with that country’s official source or a local law firm, rather than relying on general information found online.
- Decide at the contract stage which security instrument will be used for debt collection, such as a letter of guarantee, advance payment, or local registration.
- Set up a coordination model that keeps a steady flow of information between the Turkey-based legal advisor and the local law firm.
- Revisit the legal assessment periodically as the market or regulations change.
Every matter must be assessed on its own commercial and legal facts. For a company planning operations in the Middle East, obtaining an individual assessment under both Turkish law and the law of the relevant country is the soundest approach.
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