Cross-border estates
A foreign national with a flat in Barcelona, or a Spaniard with an account abroad. Once a border is involved, the first question is no longer who inherits — it is which law decides who inherits.
Which law applies
Under EU Regulation 650/2012, succession is generally governed by the law of the deceased’s habitual residence at death, not their nationality.
This surprises many people: a British national resident in Barcelona may find their estate governed by Spanish law and, within it, by Catalan civil law — reserved share included.
The Regulation does allow the deceased to choose the law of their nationality in their will. That choice is the single most important planning tool in any cross-border estate, and it has to be made during lifetime.
The European Certificate of Succession
It evidences the status of heir with direct effect across all member states, without further recognition. It greatly simplifies access to bank accounts and the registration of property abroad. We obtain it and enforce it where needed.
Double taxation and non-residents
Being governed by one law does not mean being taxed in one place. Property located in Spain is taxed here regardless of where the deceased and the heirs lived.
Spain has few specific succession tax treaties, so relief from double taxation often depends on domestic deductions.
Foreign documents
We handle the tedious part: apostilles, sworn translations, obtaining certificates abroad and coordinating with notaries and lawyers in other countries. We work in English, Spanish and Catalan.
Tell us about your case
First assessment at no cost. We tell you whether you have a case, what deadlines apply and what it would cost.
About this service.
Which law governs the estate of a foreigner living in Barcelona?+
As a rule, the law of their habitual residence — Spanish law and, within it, Catalan civil law — unless they expressly chose the law of their nationality in a will made during their lifetime.