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Cross-border succession · Honest timelines · Information, not legal advice — as at 24 August 2026

How long does inheritance take in Portugal, Spain, Italy and France?

For a straightforward estate — one property, one account, one to three heirs, nobody arguing — a realistic end-to-end range is: Portugal roughly 4–8 months, Spain 5–9, Italy 7–12, France 7–11. The heirs are usually established formally within the first two to four months; the tax filing sets the rhythm in every country; and the bank is always the last door to open, because every one of the four locks the money until the tax office has been satisfied. The single biggest lever a family controls is early paperwork: powers of attorney signed and apostilled in week one can compress every later stage.

Families always ask, and deserve a straight answer rather than “it depends”. These are honest working ranges for a straightforward estate — one property, one bank account, one to three heirs living abroad, no dispute. Complicated estates take longer; well-run simple ones land at the bottom of each range.

The honest ranges, end to end

  • Portugal — roughly 4–8 months. Heirs formally established within 1–3 months; the stamp-duty declaration is due by the end of the third month (the earliest hard deadline of the four); registration and bank release follow the tax clearance.
  • Spain — roughly 5–9 months. The six-month tax clock shapes the file (an extension exists — it must be requested in month five); the notarial deed usually signs at months 3–6; the registry itself is quick once fed.
  • Italy — roughly 7–12 months. The twelve-month filing window tempts everyone to drift; a well-run file files much earlier, because nothing is released before the declaration. The land-registry update then follows automatically.
  • France — roughly 7–11 months. Two tracks run together: the notaire’s heirship act in months 2–4 and, where there is property, his attestation towards months 5–9; the succession tax return is ours (our French practice opens in January 2027), prepared and lodged on the same clock — it is due within six months, or twelve where the death was outside France. Releases follow once the duties are settled.

What actually consumes the time

Not the law — the paperwork choreography. Four things recur in every country: obtaining a tax number for each heir; getting the death certificate into the right form (the EU multilingual standard form or an apostilled copy); the bank’s own internal checks; and — the near-universal bottleneck — the powers of attorney, which must be signed by each heir abroad and apostilled before anyone can act. A power of attorney signed in week one compresses every stage that follows; one that drifts for two months delays the whole file by two months.

The rule the four countries share: the bank waits for the tax office

In all four countries the money is the last thing to move, by design: Portuguese banks wait for the stamp-duty position to be proved, Spanish banks for the inheritance-tax receipt, Italian banks for the filed succession declaration, French banks, for heirs living abroad, for the tax office’s certificate (small balances aside). This is why we prepare the tax filing early in every country rather than treating the statutory deadline as a target — the filing is not an administrative afterthought; it is the key that opens the vault. (If the frozen account is your immediate worry: the bank has frozen the account — what now?)

What the official targets say — and what practice says

The registries themselves are quick: Portugal and Spain publish service standards measured in days or weeks, Italy’s cadastral update follows the filing automatically, and France’s land publication follows the notaire’s attestation. The elapsed months live in the steps before the registry — which is exactly where preparation, and a lawyer who runs the sequence in parallel rather than in series, earns the difference between the bottom and the top of each range.

Can the two countries run at the same time?

Yes — and they should. Nothing abroad waits for probate at home: there is no resealing, and the foreign leg runs in parallel from the week the death certificate exists. Families who start both legs together routinely finish the foreign side inside the ranges above; families who wait for the home grant first add its months to everything.

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.

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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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