When the deceased owns property in France and Spain, the succession is qualified as French-Spanish cross-border. In this case, if there is real estate, arrangements will have to be made in both countries.
Application of the law for those who died after 17 August 2015
- The law applicable to the whole inheritance: the law of the habitual residence of the deceased at the time of his death, unless the deceased had chosen his law of nationality before his death.
- Inheritance rights open to notaries: Inheritance notaries must include a list of all the deceased's property in their contract, wherever it is located. This means that French notaries will have to include the property in Spain, while Spanish notaries will have to include the property in France. Note: You should check whether the deceased made a will in France, Spain or both countries.
- Transcription in the neighbouring country of the estate: In order to be able to register with the Spanish property registry or the Service de la publicité foncière in France, to accept the inheritance, you must appoint a local notary.
All you need is the European Certificate of Succession from the first notary responsible for the inheritance (the form provided for in this Regulation). There is no need for an apostille or translation. The certificate simplifies the process, as if the deceased died before 17 August 2015, it must carry more notarised documents, and all documents must be apostilled and translated by a sworn translator.
For the Spanish case, all French heirs must have a foreign identification number (NIE) and come in person to present themselves to a Spanish notary. If they cannot come, a translated letter of authorisation must be provided. All heirs resident in France must appoint a fiscal representative in Spain to pay the taxes. The representative must be a natural person resident in Spain.
Stay tuned to our blog as we will soon be expanding the information in more detail on the whole subject of succession!