Cross-border · Costs · Information, not legal advice — as at 23 August 2026
What it costs to settle an inheritance in Spain, Portugal, France or Italy — who pays, and why it costs more
Settling an inheritance abroad — the probate of a house in Spain, an apartment in Portugal, or a family home in France or Italy — costs more than dealing with an estate at home — not because of extra tax, but because there is more work involved (since a 2014 EU court ruling, Spain may not tax non-resident heirs more heavily than residents). We charge a single fixed fee, agreed in writing before we start — not an open-ended hourly clock — and we keep our fee separate from third-party costs like notary and registry fees. Because there is no “estate pot” abroad to bill, the family member who instructs us pays, and is normally reimbursed their fair share from the estate when it is divided.
Why a cross-border estate costs more — and takes longer
It is not a tax penalty for being foreign. It is that the same legal result needs more steps when the heirs live abroad — each of these is real, unavoidable work a domestic estate doesn’t need:
- A tax number for every heir — an NIE in Spain, an NIF in Portugal — before they can sign the deed, settle tax, or have an asset registered.
- Foreign documents made usable — the death certificate, the will, any grant of probate and the powers of attorney must be apostilled in the country that issued them and sworn-translated.
- Powers of attorney, so no one flies out — a bilingual PoA per heir, signed before a Notary Public near them at home (a short local appointment, not a flight abroad), then apostilled. (A formal notarised signature, not a quick online one.)
- Extra bank checks on non-resident parties; and coordination across offices in more than one country.
Because these run in sequence, a foreign estate commonly takes several months longer than a domestic one — often four months to a year. And the number of heirs matters: each extra heir is another tax number, another PoA, and (in Spain) another tax return — so our fixed fee covers a set number of heirs, with a clear set amount for each additional one. (A practical example of the friction: a Spanish NIE can take months via a consulate — so, with a power of attorney, we obtain each heir’s NIE from inside Spain instead, avoiding the queue.)
A fixed fee, not the hourly clock
When a lawyer charges by the hour, you can’t know the cost until the work is finished — and you carry the risk if it runs long. We do the opposite: a single fixed fee for a defined piece of work, agreed in writing before we start. If it takes us longer than expected, that’s our problem, not yours — the fee doesn’t move, and you can ask as many questions as you need without watching a meter. We also publish our prices, which is unusual in this field; most firms quote only after a private enquiry. The one honest exception is genuine complexity that can’t be known up front (a trust, a dispute, several countries at once) — there we agree a fixed price once we understand the estate, or explain plainly how it will be charged. There is always a written quote before you instruct us.
Two budgets — kept separate
There are really two different things to pay for, and we always keep them apart:
- Our fee — the fixed, agreed number for the legal work.
- Third-party costs — official charges that go to others, not us: notary and registry fees, any tax, apostilles, and any sworn translation a foreign authority requires. (In Portugal we certify standard translations in-house, so those are part of our fee, not an extra.)
A headline price that quietly folds these together isn’t really transparent. We show them as two columns on purpose.
Who pays — and who is reimbursed
Abroad there is no executor holding an estate “pot” to bill first, and the deceased’s accounts are frozen. So the family member who instructs us is our client, and our fee is payable by them. The good news: the cost of administering an estate is, in principle, a charge on the estate — so the person who fronts it is normally entitled to be reimbursed their fair share when the estate is divided. We say “in principle” deliberately: that reimbursement covers costs incurred in the common interest of all the heirs, it depends on the estate having the funds and the heirs settling up at the division, and it is ultimately a matter between the heirs — it is not something we can guarantee, and it doesn’t change the fact that our fee is owed by whoever instructs us.
One important exception: where the person who died lived in the UK and their estate is being wound up there by a personal representative — often when a UK solicitor refers the foreign side to us — the cost of the foreign leg is a testamentary expense of the UK estate, usually met by the estate through that solicitor, not advanced personally by a grieving family member.
The no-surprises promise
Our fee assumes a standard matter. If something arises that would increase it, we explain it in full — the issue, the extra work, the added cost — and agree it with you before doing the work. You always have a written quote before you instruct us, and you can ask for an update at any time.
The short version
A cross-border estate costs more because there is more work involved — not more tax. We charge a fixed fee, agreed and published up front, kept separate from third-party costs. The person who instructs us pays and is normally reimbursed from the estate at the division — in principle, between the heirs, not a guarantee — unless a UK estate is paying, in which case it comes through the UK solicitor. No hourly clock, no bill-shock.
And one more thing about the money itself: every payment you make to us is a receipted fee. The official costs are paid by you directly to the notary, the registry or the tax office — prepared by us so each is a five-minute task. We never hold client or estate money. Why we never hold your money →