Inheritance & Succession in Portugal

How Portuguese Succession Law Affects Foreign Owners and Heirs

Property, bank accounts or investments in Portugal can bring part of your estate under Portuguese law, even if you live in the United States. Portugal applies the EU Succession Regulation (Brussels IV), under which the law of a person's habitual residence generally governs the succession unless that person has chosen the law of their nationality. Portuguese law also protects certain close relatives through forced-heirship rights (legítima), and transferring real estate to heirs involves Portuguese notaries and registries. Planning ahead can spare your family delay and expense.

Our Portuguese Succession and Estate Planning Services

• Structuring Portuguese-law wills and explaining forced-heirship rights (legítima) for non-residents.
• Representation in registering Portuguese real estate, property tax filings (IMI and IMT) and clarifying tax status for foreign nationals.
• Coordination with Portuguese notaries (cartório) and registry authorities to transfer property to heirs abroad.
• Pre-succession tax planning for U.S. citizens who own Portuguese assets, including whether any treaty relief is available.

Frequently Asked Questions About Property and Inheritance in Portugal

Which country's law applies to my Portuguese property?

That depends on where you live and whether you have chosen the law that will govern your estate. Under the EU Succession Regulation the default is generally the law of your habitual residence at death, but you can often choose the law of your nationality. We review your situation and explain your options.

Can I leave my Portuguese property to anyone I choose?

Not always. Portuguese law reserves a share of an estate for certain close relatives, so forced-heirship rules can limit how assets governed by Portuguese law are distributed. Planning ahead helps your family understand what to expect.

How is Portuguese property transferred to heirs who live in the United States?

Transfers generally involve a Portuguese notary and the property registry, and the heirs' tax status in Portugal has to be clarified. We coordinate with Portuguese professionals so the process is as manageable as possible for heirs abroad.

Related Resources

• International estates and inheritance
• Cross-border inheritance planning: choosing the right law for your estate
• Other country guides: Spain, Italy, France and Germany

Contact us today for a free initial consultation on your European estate or cross-border succession matter. Our bilingual team and international network help ensure a smooth transition for your estate across the U.S. and Europe.

This page is general information, not legal advice. Foreign law changes, and every estate is different.