Spanish Will vs Foreign Will – What Expats Need to Know

🇪🇸 Living in Spain or Owning Property? You Need to Plan Ahead

If you’re a foreigner living in Spain or own assets here — like a home, bank account, or business — you’ve likely wondered:

“Do I need a Spanish will, or is my foreign will enough?”

The short answer: you can use a foreign will, but having a Spanish will is strongly recommended if you want to avoid legal delays, disputes, or forced heirship problems.


⚖️ Spanish vs Foreign Will – Key Differences

Feature Foreign Will Spanish Will
Valid in Spain? ✅ Yes (with conditions) ✅ Yes (automatic)
Must be translated? ✅ Yes ❌ No
Must be apostilled/legalized? ✅ Usually ❌ No
Inheritance handled faster? ❌ No – delays common ✅ Yes – streamlined process
Enforces chosen law? ❌ Not always ✅ Yes – clearer declaration possible

📜 Can Foreigners Use a Foreign Will in Spain?

Yes, but with some important caveats:

  • It must be translated into Spanish by a sworn translator

  • It must be legalized or apostilled

  • It may be subject to forced heirship laws under Spanish civil code unless you explicitly state which country’s law applies

💡 Without a clear clause choosing your national law, Spanish law may override your wishes — especially if you are resident in Spain at the time of death.


🇪🇸 Why Draft a Spanish Will as a Foreigner?

✔️ Recognized immediately by Spanish notaries and registries
✔️ Avoids delays and complications in inheritance processing
✔️ Can coexist with a will in your home country
✔️ Allows you to choose the law of your nationality (under EU Regulation 650/2012)
✔️ Easier and cheaper for heirs to execute
✔️ Can be updated quickly if circumstances change


🏛️ How Are Wills Executed in Spain?

  1. Locate the will (check Spain’s Wills Registry – Registro de Últimas Voluntades)

  2. Obtain death certificate and certificate of last will

  3. Go to a notary for declaration of heirs

  4. Execute the inheritance deed (escritura de aceptación)

  5. Pay inheritance tax (Modelo 650)

  6. Register assets in heirs’ names

🔁 This process is much faster with a Spanish will already on file.


⚠️ Forced Heirship: What If You Don’t Plan Ahead?

If you:

  • Die without a will

  • Have a will that doesn’t clearly choose your national law

  • Are considered tax resident in Spain

Then Spanish forced heirship rules may apply:

  • Children must receive at least two-thirds of the estate

  • Spouses receive a life interest in one-third, not full ownership

This may override your intentions, especially in blended families or cross-border estates.


📍 Does a Spanish Will Replace My Foreign One?

No — you can have both, as long as:

  • They are not contradictory

  • The Spanish will explicitly refers only to assets located in Spain

  • Your lawyer reviews both wills for consistency


✅ Best Practice for Expats & Property Owners

  1. Draft a separate Spanish will for assets located in Spain

  2. Include a choice of law clause (your nationality’s law)

  3. Have your Spanish will signed before a notary

  4. Register the will with the Spanish Wills Registry

  5. Make sure your heirs know where it’s stored


⚖️ How We Help

Our legal team:
✅ Drafts Spanish wills that align with your intentions
✅ Ensures compatibility with your foreign will
✅ Registers your will with the official registry
✅ Protects your heirs from disputes, delays, or tax issues
✅ Explains all options clearly in English, French, German, or Dutch


📞 Protect Your Spanish Assets with a Legally Binding Will

Avoid legal conflicts, delays, or surprises. Our English-speaking lawyers make it easy for expats to draft a valid Spanish will — fully compliant and tailored to your needs.

👉 Contact us now to draft your Spanish will with peace of mind.

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