Protection & Succession

International Succession

When a family has assets, nationalities or residences in more than one country, inheritance stops being simple: you must know which law applies, how the courts interact and how to avoid clashes between rules. International succession planning anticipates all of this to protect the estate and the family.

How it works

Mapping the family's assets, nationalities and residences.
Determining the applicable law and, where possible, choosing the law of nationality (professio juris).
Drafting wills coordinated across jurisdictions and tax planning of the transfer.

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Legal framework

EU Regulation no. 650/2012 (Succession): as a rule the law of the last habitual residence applies, but the law of nationality may be chosen.
Portugal has forced heirship — the share of protected heirs (spouse, descendants and ascendants) safeguarded in the Civil Code.
Each country has its own inheritance-tax rules; we always confirm the applicable framework.

In depth

Which law applies to the inheritance?

In the European Union, EU Regulation no. 650/2012 (Brussels IV) provides that, as a rule, the law of the country of the deceased's last habitual residence applies to the whole succession. But it allows something decisive: choosing, in a will, the law of your nationality (professio juris).

That choice can avoid surprises — for example, applying Portuguese law, with its forced heirship, or another law, depending on the family's goals. For those with assets in Portugal and Brazil, coordinating the two legal systems is essential.

Forced heirship and the limits of the will

In Portugal, the Civil Code protects forced heirship — the share of the estate reserved to protected heirs (spouse, descendants and ascendants), which cannot be freely set aside. Only the disposable share can be left by will to third parties.

Planning a succession is, to a large extent, working within these limits: distributing the disposable share, using lifetime gifts and holdings, and coordinating wills so the wishes take effect without breaching the law.

Frequently asked questions

Can I choose which law governs my inheritance?

In the European Union, Regulation 650/2012 lets you choose the law of your nationality, in a will, instead of the law of residence.

What is forced heirship?

It is the part of the estate reserved by law to certain heirs (in Portugal, spouse, descendants and ascendants), which cannot be freely set aside.

I have assets in Portugal and Brazil. How does it work?

You must coordinate both laws: the one applicable to the succession and the local rules for each asset. A good plan avoids duplicated proceedings and conflict between heirs.

Does a single will work for several countries?

Sometimes, but often it is better to have wills coordinated by jurisdiction. We assess what best protects the family and respects each law.

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