Casza Answers
How Do Inheritance Laws Affect Property Abroad?
Quick Answer
Some countries have forced heirship laws that override your will. France and Italy require portions go to children. Spain allows foreign law to apply. Always plan ahead.
Inheritance laws vary dramatically and can surprise foreign property owners.
Forced Heirship Countries
France
Italy
Spain
Portugal
Best Practice
- Specifically for property in that country
- Works alongside home country will
- Company ownership (where legal/beneficial)
- Life insurance
- Gifting strategies
- EU residents can choose nationality law
- Must be explicitly stated
Tax Considerations
Inheritance tax also varies: