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Cross-Border Wills in Portugal: How to Protect Your International Estate

Oct 15, 2025

For foreign residents living in Portugal, having a valid will is one of the most effective ways to ensure that their assets are managed and distributed according to their wishes.

The EU Succession Regulation

The European Succession Regulation (Regulation (EU) No 650/2012) applies in Portugal and creates a unified legal framework for cross-border inheritances within the European Union.

Under this regulation, the law governing a person’s succession is, by default, that of their habitual residence at the time of death.

This means that if someone is tax resident in Portugal, Portuguese law will usually apply to their entire estate — unless they choose otherwise.

Choosing Your National Law

The regulation offers an important option: anyone may choose the law of their nationality to govern their succession.

For example, British, South African, or North American citizens living in Portugal can state in their Portuguese will that their estate should be governed by their national law.

This can be especially useful since Portuguese inheritance law includes mandatory “forced heirship” rules that reserve a fixed share of the estate for close relatives such as spouses, children, or parents.

By choosing their national law, many people gain greater freedom to decide how their assets will be distributed.

Why Make a Will in Portugal

Having a will drafted in Portugal also brings practical advantages. It allows you to:

  • Clearly define how your Portuguese assets should be handled.
  • Appoint representatives to manage your estate locally.
  • Avoid potential legal conflicts between jurisdictions.
  • Prevent delays for your heirs.

 

Overall, this makes the inheritance process smoother and more efficient.

A Practical Step for International Residents

For anyone living in Portugal with international ties, preparing a will under the EU Succession Regulation ensures:

  • Legal certainty
  • Respect for personal wishes
  • Easier estate management for heirs in Portugal and abroad

 

It combines flexibility with security, allowing you to align your estate planning with Portuguese procedures while preserving your own national legal traditions.


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