Solving the English Probate Puzzle for Spanish Property Owners
Navigating English probate for Spanish property causes friction in Spanish notarial and registration practice for one simple reason: the two systems start from opposite assumptions about how to prove a valid succession. Understanding the complexities of English probate for Spanish property is essential for any executor or owner looking to avoid lengthy legal delays. In England and Wales, a […]
The Succession Divide: Navigating Cross-Border Inheritance for Modern Families
The traditional nuclear family, married parents, biological children, assets in one country, was once the bedrock of European succession law. Today, it’s increasingly the exception rather than the rule. Modern private wealth is defined by blended households, same-sex couples, long-term cohabitation without marriage certificates, and assets scattered across the English Channel and the Mediterranean. Families […]
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 […]
Practical Steps for Handling Wills and Trusts Between the UK and Spain
Understanding the Challenge Managing estates across borders presents unique challenges, particularly between the UK and Spain. With over 293,000 British citizens residing in Spain and countless others owning holiday homes, the intersection of these two legal systems has become increasingly important. The fundamental differences in how these countries approach inheritance law can create significant complications […]
