Conflict of Laws
Understanding Which Law Applies to Your Inheritance in Spain
Inheritance in Spain » European Succession »
When Multiple Countries Are Involved, Which Law Governs the Inheritance?
Cross-border inheritances often raise one key question: Which country’s law actually applies? This is especially relevant for families with assets in Spain but wills, residency or heirs in other jurisdictions such as the UK, Ireland, the US, Canada or Australia.
Our role is to analyse how Spanish succession law interacts with foreign wills and foreign legal systems, ensuring the inheritance is handled under the correct legal framework and avoiding conflicts that lead to delays or challenges.
We assist foreign beneficiaries, executors and solicitors in understanding legal jurisdiction, applicable law under the EU Succession Regulation, and how Spain interprets foreign documents and wills.
Our Expertise in Cross-Border Conflict of Laws
We analyse and resolve legal conflicts arising when more than one jurisdiction may apply to an estate. This includes:
- Determining applicable law under EU Regulation 650/2012 for non-EU residents with property in Spain.
- Assessing the validity of foreign wills and how they interact with Spanish succession law.
- Resolving conflicts between domicile, nationality and habitual residence for inheritance purposes.
- Coordinating with UK, Irish, US, Canadian and Australian probate to ensure documents are recognised in Spain.
We provide clear, jurisdiction-specific guidance so beneficiaries know exactly how their rights are determined under Spanish and international law.
Why Understanding Applicable Law Matters
Misunderstanding which law governs the estate can lead to delays, disputes or invalid distributions. We prevent those situations with precise legal analysis.
01
Correct legal foundation
We identify whether Spanish law or foreign law applies — and why.
02
Recognition of foreign documents
We ensure wills, grants and certificates from abroad are accepted in Spain.
03
Avoiding legal conflicts
We prevent contradictory claims based on multiple national laws.
04
Smooth cross-border process
Your inheritance proceeds without jurisdictional obstacles.
Who We Assist
We support families, heirs and international law firms managing estates with assets in Spain and legal connections to:
- UK & Ireland
- United States
- Canada
- Australia
- New Zealand
- South Africa
- EU Member States
- International private client solicitors
If your situation involves more than one country, we can assess it and provide clear direction.
International estates do not need to be confusing.
We clarify which law applies and how it affects your rights — ensuring a legally sound inheritance process.
How We Resolve Cross-Border Law Conflicts
A structured and legally robust approach:
1
Jurisdiction analysis
We determine which country’s law governs the inheritance based on EU regulations, nationality, residence and the will.
2
Document compatibility
We ensure wills, grants, letters of administration and probate documents are valid in Spain.
3
Legal alignment
We resolve conflicting interpretations between Spanish and foreign rules.
4
Implementation in Spain
We move forward with the Spanish inheritance procedure once jurisdiction is confirmed.
Contact our team
We are here to help you navigate your legal or administrative matter in Spain.
If you need personalised guidance, you can send us a short message and our team will:
- Review your enquiry
- Clarify the steps and requirements
- Identify what you can do next
- Provide direct assistance suited to your situation