Spain Confirms English Law Applies Without Probate in Cross-Border Succession: Key Resolution for STEP Practitioners
A groundbreaking resolution from Spain’s Directorate-General for Legal Security and Public Faith, issued on 4 August 2025, has provided crucial clarification for STEP practitioners managing cross-border estates between the UK and Spain. This decision establishes clear precedent that English law can govern Spanish asset inheritance through implied choice of law provisions, eliminating the need for […]
The True Essence of Trusts: A Personal Reflection from an Anglo-Spanish Perspective
Much is said about trusts today : especially by corporate trustees and continental-trained lawyers : yet much of it misses the essence of what a trust really is. For many, a trust has become a compliance product, something to be administered within the framework of regulation and reporting. For others, particularly within civil law traditions, […]
Trusts in Spain: An Incoherent Legal and Tax Approach
A trust is a legal relationship originating in common law whereby a person (the settlor) transfers assets to another (the trustee) to hold and manage for the benefit of one or more beneficiaries. The trustee holds legal title, while the beneficiaries enjoy the equitable or beneficial interest. Although often compared to civil law concepts such […]
