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Inheritance with real estate in two countries

Inheritance with property in two countries: notarial records, European Certificate of Succession, apostille exemptions and useful translations.

Understand the process
Editorial lead : CertiDocs Team7 sources

List assets and recipients

Link to this section

For each country, list the asset address, title references and relevant notary or registry. Have the estate’s notary confirm which records prove your rights and which serve local property formalities. This list helps select the necessary translations.

Official sourceYour Europe - Managing a cross-border inheritance

The European certificate may help

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For an estate under Regulation 650/2012 in participating states, the European certificate can prove heir status abroad. It is optional and does not replace every property record. In Belgium, the notary is competent to issue it. Check the copy’s expiry date before your appointment abroad.

Official sourceEUR-Lex - Succession Regulation 650/2012, Articles 62, 70 and 74e-Justice Portal - Belgian authority issuing the European Certificate of Succession

Check exemptions before authentication

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Do not automatically apostille every record. Article 74 exempts documents issued under the Succession Regulation from legalisation and similar formalities. Confirm each recipient’s language and format separately. For other records, check the rules for the document and countries before translation.

Official sourceEUR-Lex - Succession Regulation 650/2012, Articles 62, 70 and 74FPS Foreign Affairs - Legalisation and apostille of documents

Documents to prepare

  • Death certificate and family records clearly identifying the heirs
  • Will, inheritance certificate or other records fixing the succession chain
  • Title deeds, cadastral references or useful property records in each country involved
  • Mandate or power of attorney if an heir must be represented or needs to sign remotely
  • Check exemptions and accepted languages for the requested records. Apostille or legalisation of the original only if required; sworn translation only if requested, with its formalities checked separately.

Steps to follow

  1. Open the inheritance

    Secure the death certificate, the will search and the identification of the heirs.

  2. Separate the properties

    Gather country by country the title records, cadastral references and useful records for each property.

  3. Check exemptions and translations

    First check authentication exemptions, then confirm the records, languages and formats to translate.

  4. Coordinate signatures

    Check who signs, under which mandate or power, and before which authority or notary.

Good to know

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Frequently asked questions

+Is the will enough to deal with real estate in two countries?
No. You also need proof of ownership, identification of the heirs and the authority to represent or sign at each relevant step.
+Do you always need two notaries?
Not always, but you do need to reason with the authorities actually competent in each country. The Spanish consular guidance shows that coordination is not a theoretical problem.
+Do all property titles need translation?
No. Translate what the authority or notary actually needs to use. Otherwise, you are mostly generating costs.
+Can a power of attorney simplify everything?
It can help with signatures or one-off representation, but it does not replace heirship or the coherence of the succession chain.
+Why does this kind of inheritance fall behind so quickly?
Because the file has to survive several administrative and notarial readings at once. The first weak record makes everything else stumble.

Official source

Official sources used

The references below are the public sources used to document this page. The competent authority always retains the final decision.

Official sourcee-Justice portal - Succession en BelgiqueOfficial sourceBelgium.be - Décès à l'étrangerOfficial sourceBelgian embassy in Spain - Notariat et successionOfficial sourceYour Europe - Managing a cross-border inheritanceOfficial sourceEUR-Lex - Succession Regulation 650/2012, Articles 62, 70 and 74Official sourcee-Justice Portal - Belgian authority issuing the European Certificate of SuccessionOfficial sourceFPS Foreign Affairs - Legalisation and apostille of documents

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