When an estate involves more than one European country, the rules on which law applies, where the succession is handled and how assets in Spain are dealt with can become confusing very quickly — especially if family members live in different jurisdictions.
Clarity and structure for cross-border estates involving Spain
Modern families rarely fit neatly inside one country’s borders. It is increasingly common to see a British or Irish national who lived in Spain, held assets in several EU states, and made a will in yet another jurisdiction. When that person passes away, the question is not only who inherits, but which law applies, where the succession is dealt with and how Spain fits into the overall picture.
Our role is to interpret the European succession rules in a practical way, explain how they affect your Spanish assets, and put in place a coherent strategy so that the estate can be administered and distributed efficiently across borders.
If you already know what you need, you can go straight to European Certificate of Succession, International Wills or Conflict of Laws in European Succession.
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Families dealing with cross-border estates tell us things like:
European succession law brings opportunities — such as the option to choose the law of your nationality — but it also introduces complexity when the rules are not fully understood or applied consistently.
Our work is to bring the different pieces together: European regulations, national law, wills made in several jurisdictions, Spanish real estate and the expectations of the heirs. The aim is simple: a coherent, legally sound plan for dealing with the estate that everyone can understand.
We examine the deceased’s nationality, residence, wills and assets to clarify which law governs the succession and where the main proceedings should take place.
We ensure that Spanish property and bank accounts are dealt with in a way that is consistent with the overall European succession and any foreign probate or grants.
We advise when a European Certificate of Succession is useful, obtain it where possible and use it to prove heirship and powers in Spain and other EU countries.
We review existing wills and estate plans from different jurisdictions to avoid contradictions and ensure Spanish procedures follow the intended distribution.
Instead of coordinating several professionals separately, you work with one team in Spain that liaises with lawyers and notaries in other jurisdictions.
The result is a succession that feels structured and manageable, rather than a patchwork of isolated procedures in different countries.
We focus on cross-border families
Many of our clients have roots in one country, property or residence in Spain and family members spread across several jurisdictions. We are used to dealing with estates that do not fit into a single legal system.
Real results
More than 15 years working with international estates
We have assisted families from the UK, Ireland, the US, Canada, Australia and across Europe in managing cross-border successions that include Spanish property and other assets located in Spain.
Consistent feedback from clients
This is more than handling a Spanish inheritance — it is about making sense of a European succession that involves several legal systems.
We analyse the situation and explain, in plain English, which country’s law governs the succession and what that means for Spanish assets.
We help prevent parallel actions that do not align with each other, saving time, costs and frustration for the heirs.
From notaries and registries to banks and tax authorities, the Spanish part of the succession is handled locally for you.
You receive regular updates on how the Spanish procedures fit with what is happening in other countries, so you always see the full picture.
Once the succession is complete, Spanish and foreign elements are aligned and the heirs can administer, use or sell assets with legal certainty.
Which country’s law applies to the estate?
It depends on factors such as the deceased’s last habitual residence, nationality and any valid choice of law made in a will. We review these elements and explain which law governs the succession and how Spanish assets are affected.
Do we always need a European Certificate of Succession?
Not always. In some cases, local documents are sufficient. In others, a European Certificate of Succession can simplify matters across several EU countries. We assess whether it is beneficial in your specific situation.
What happens if there are wills in more than one country?
Multiple wills are common in international estates. We examine how they interact, whether they deal with different assets or territories and how they should be interpreted so that Spanish procedures follow the intended distribution.
Can different heirs apply different laws to their shares?
No. The question of applicable law is addressed at the level of the estate, not heir by heir. We clarify which law applies to the succession as a whole and how that affects each person’s position.
Do we need lawyers in more than one country?
Often yes, especially when assets and proceedings exist in several jurisdictions. Our role is to manage the Spanish side and coordinate with your existing advisers abroad so that everyone is working from the same legal framework.
Take the next step
You can send us a brief description of your situation, and we will: