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Cross-border · For families · Information, not legal advice — as at 19 June 2026

Can my UK solicitor handle the Portuguese assets?

Your UK solicitor can run the estate at home, but they cannot act on the Portuguese property or accounts directly — those transfer only through the Portuguese process, before a Portuguese notary and registry, in Portuguese. The usual, sensible arrangement is that your solicitor keeps the home estate and we handle the Portuguese leg alongside them. You don’t have to choose between them.

Why the home solicitor can’t do the Portuguese side

A UK solicitor is qualified in UK law and can deal with UK assets, obtain the grant, and administer the estate at home. But a Portuguese property doesn’t move on a UK grant. Transferring it means the Portuguese steps — the declaration of heirs (habilitação), the stamp-duty return (Imposto do Selo) and registration into the heirs’ names — done in Portuguese, before Portuguese authorities. A family abroad usually has a lawyer registered in Portugal do them under a power of attorney. That’s a different qualification, not a reflection on your solicitor.

How it actually works — two firms, one matter

In practice the work splits cleanly:

  • Your UK solicitor keeps the relationship and handles the home estate — the grant, the UK assets, the UK tax position.
  • We handle the Portuguese leg — under a power of attorney, remotely, in plain English — and liaise with your solicitor so the two sides line up. Where your will is English, we produce the Certificate of English Law the Portuguese notary needs, in Portuguese, in-house — included when we handle the estate (Succession Administration); otherwise a separate fixed fee, quoted before we start.

Nothing is lost in the gap between them, because the person doing the Portuguese work is also a solicitor who understands the English will.

A note for solicitors

If you’re the solicitor reading this on a client’s behalf: you keep the client and the home estate; we take only the cross-border leg and hand back. You can refer the whole local matter or instruct us for a single piece — including a certificate of Portuguese law for an England & Wales grant.

If you are the solicitor: the full professional walkthrough is the English solicitor’s guide to the Portuguese estate, and how to refer or instruct us takes two minutes.

One thing to check first

Which country’s succession law applies — English or Portuguese — depends on where the person was habitually resident and on whether the will chose a law (Brussels IV), not on where the will was made. It’s worth confirming early, because it changes who leads and what the estate looks like. We check it at the outset.

How Carroll Law can help

We handle the Portuguese, Spanish, Italian or French side of an estate end-to-end, in plain English, for a fixed fee agreed before we start — and where your loved one lived abroad, we work alongside your home-country solicitor: their grant deals with the estate at home, while the assets abroad pass through each country’s own process — a home grant has no direct effect there, and there is no resealing. Transferring a property after a death is a fixed €4,000–€5,000 + VAT, depending on the country.

See all our fixed prices · More guides

This article is general information, not legal or tax advice, and does not create a lawyer–client relationship. For advice on your situation, instruct a lawyer admitted in the relevant jurisdiction. Reviewed by Colin Carroll.

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