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Portugal · Cross-border succession · Information, not legal advice — as at 19 June 2026

Does a UK will work in Portugal?

Yes — a valid English (or other UK) will is recognised in Portugal and can govern your Portuguese assets. But it doesn’t act on them by itself: it has to be translated and explained to the Portuguese notary through a certificate of the law it was made under. And which country’s succession law applies — English or Portuguese — is a separate question decided by Brussels IV, not by where the will was written.

Recognised, but not self-executing

Portugal accepts a foreign will that was validly made under the law of the place where it was signed — an English will properly executed in England is formally valid here. What it cannot do is move a Portuguese property on its own. To be acted on, the will is explained to the Portuguese notary through a Certificate of English Law — a short legal statement, in Portuguese, that the will is valid and who inherits under it. Where there is an English grant it helps as supporting evidence, but the Portuguese steps need not wait for it. We produce that certificate in-house, ready to file — included when we handle the estate (Succession Administration); otherwise a separate fixed fee, quoted before we start.

The deeper question: which law decides who inherits?

Recognising the will is not the same as deciding which country’s succession law governs it. Under the EU Succession Regulation (Brussels IV), the default is the law of the country where you were habitually resident when you died. So if you’ve made Portugal your home and didn’t say otherwise, Portuguese succession law — including its forced-heirship rules — may apply despite your English will. The fix is usually a single clause expressly electing English law under Brussels IV.

So, in practice

A UK will works in Portugal — but to be sure it does what you intend, you want a valid will, ideally an express choice-of-law clause, and, when the time comes, a certificate of law to put it into effect here (with the English grant as supporting evidence, if there is one) — remembering that the will decides who takes; only the Portuguese process can transfer. We handle the Portuguese side of all of that.

How Carroll Law can help

We handle the Portuguese 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 Portuguese assets pass through Portugal’s own process — a home grant has no direct effect here, and there is no resealing. Transferring a Portuguese property after a death is a fixed €4,000 + VAT.

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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