Cross-border Succession
Cross-border succession planning for expats and international families: applicable law, choice of law and coordinating Portuguese and foreign estates.
Provided by VPA — Venture Partners Advogados, a law firm registered with the Portuguese Bar Association, with offices in Lisbon and Rio de Janeiro.
Overview
For clients with assets or heirs in more than one country, VPA plans the succession across borders. We advise on which law governs the succession under the EU Succession Regulation (No. 650/2012), on the possibility of choosing the law of your nationality (professio iuris), on international wills, and on coordinating the Portuguese estate with foreign heirs, executors and tax authorities to avoid conflicts and double taxation.
Common processes
- Applicable law (EU Regulation 650/2012)
- Choice of law (professio iuris)
- International wills
- Heirs abroad
- Cross-border tax coordination
- Recognition of foreign decisions
Frequently asked questions
Which law governs my succession in Portugal?
Under the EU Succession Regulation, it is generally the law of your habitual residence, unless you have chosen the law of your nationality. We confirm what applies to you.
Can I choose the law of my country?
Yes. You can elect the law of your nationality to govern your succession (professio iuris), which we set out in your will.
I have heirs abroad — is that a problem?
No, but it needs coordination. We manage the Portuguese steps and work with foreign heirs and advisors.
Will I be taxed twice on the inheritance?
It depends on the countries and any conventions. We plan to reduce the risk of double taxation.
Related areas
Specialists
Contact
For advice on this service, contact VPA — Venture Partners Advogados, Lisbon.