Cross-border succession · Portugal · Spain · Italy · France
When an inheritance crosses two countries, you need one lawyer who knows both sides.
An English will and a house in the Algarve. A French notaire and a UK pension. We are the rare firm where one lawyer is the regulated local advocate in Portugal, Spain, Italy and France and understands the home-country will — so nothing falls in the gap.
The cross-border problem — said plainly
Most international estates are handled by two firms working blind. Your solicitor at home knows your will but cannot act on the foreign property; a local agent abroad can move the property but has never read your will and isn’t a regulated lawyer. Documents get translated twice, re-sworn, posted back and forth, and the months add up. Every hand-off is a place for something to go wrong — and a place where no one is quite accountable.
How we are different — one lawyer, both systems
Your matter is signed personally by Colin Carroll — a lawyer of 20 years’ standing who began as an Irish and English solicitor, and so knows the English and Irish probate process from the inside — now the registered, insured European lawyer under EU Directive 98/5/EC in Portugal, Spain, Italy and France — the Ordem dos Advogados, the Ilustre Colegio de Abogados, the Ordine degli Avvocati and the Ordre des avocats — with professional-indemnity insurance in each. The same person reads the home-country will and is the advocate who acts on it before the notary and the registry — in the national language, without an outsourced certificate or a sworn translation in the chain.
Which country's law decides who inherits?
When someone dies owning assets in more than one country, the EU Succession Regulation (“Brussels IV”) decides which country’s law governs who inherits. By default it’s the law of the country where the person was habitually resident when they died — so a British couple who truly made Portugal their home will, by default, have Portuguese succession law applied, including its forced-heirship rules. A will can elect the law of your nationality instead — but it must be done expressly, and it has limits.
Two honest caveats we’ll always tell you about: Brussels IV governs succession, not tax; and habitual residence is judged on the whole picture of your life. France adds a further wrinkle — a 2021 rule can let French children claw back a reserved share even where you elected another country’s law (now read narrowly, though not yet tested in the courts).
Brussels IV — choosing your own country’s law, and what it can’t do · Forced heirship across the four countries
What it costs
Cross-border administration is a fixed fee agreed in writing before any work begins — €6,500 + VAT for a clean two-system estate, or €8,500 + VAT where the estate is multi-asset. Spain, Italy and France scale by country and are quoted the same way. Third-party costs and your home solicitor’s own fees are never included, and are always shown up front.
All four countries’ fixed prices, side by side · Portugal in full
Common questions
Can one lawyer handle an inheritance in two countries?
Yes — that is exactly what we do. Colin Carroll is the registered, insured lawyer in Portugal, Spain, Italy and France and understands the English/Irish will from the inside, so the same person reads the home-country will and acts on it before the foreign notary and registry — no second firm, no outsourced certificate in the chain.
Do you work alongside my solicitor at home?
Yes. Your solicitor at home deals with the home estate; we handle the foreign side and coordinate with them — their grant runs the estate at home and serves as supporting evidence abroad, where it has no direct effect (there is no resealing in our countries). Their fees are separate and always shown up front.
Which country's law decides who inherits?
Under the EU Succession Regulation (Brussels IV) the default is the law of the country where the person was habitually resident at death — so a British couple who made Portugal or Spain their home may have local forced heirship applied unless they expressly elected their national law in a will. Brussels IV governs succession, not tax.
Do I have to travel abroad to deal with the estate?
No. We act under a power of attorney and handle the foreign side remotely, in plain English.
What does cross-border estate administration cost?
A fixed fee agreed in writing before any work begins — €6,500 + VAT for a clean two-system estate, or €8,500 + VAT where it is multi-asset. Spain, Italy and France scale by country and are quoted the same way; third-party costs and your home solicitor's fees are never included.
The four countries
One firm, one standard, one accountable lawyer — with a standing local team in each country — across all four.
Professional advisers: refer a client or instruct us for one cross-border slice.