Hugh Phelan Solicitor & Notary Public — Douglas, Cork
Wills · Probate · Enduring Power of Attorney · Notarisation & Apostille
📞 021-489-7134 Book Appointment →Many Cork families own property abroad — in Spain, France, Portugal, the UK or further afield. Handling foreign property in an Irish will is more complex than most people realise.
Does Your Irish Will Cover Foreign Property?
It depends. An Irish will can cover foreign property — but whether it will be recognised and how it will be administered depends on the law of the country where the property is located.
The EU Succession Regulation (Brussels IV)
For EU countries (except Denmark), the EU Succession Regulation applies. It allows EU residents to choose the law of their nationality to govern their entire estate. An Irish citizen living in Ireland can elect Irish law to govern their European property through their Irish will.
UK Property Post-Brexit
The UK is no longer subject to EU Succession Regulation. UK property now requires separate consideration. For significant UK property holdings, a separate UK will may be advisable.
Spanish Property — A Common Issue for Cork Families
Spain has complex inheritance laws including "forced heirs" provisions. An Irish will with an EU Succession Regulation election can often address Spanish property — but specialist advice is strongly recommended for any Spanish real estate holding.
| Country | Approach |
|---|---|
| EU countries (Spain, France, Portugal, Italy) | Consider EU Succession Regulation election in Irish will |
| UK | Consider separate UK will for UK property |
| USA | Separate US will or estate plan typically needed |
| Australia | Separate Australian grant may be required |
Frequently Asked Questions
Does my Irish will cover my Spanish property?
Potentially — through an EU Succession Regulation election in your Irish will. However, Spanish property requires specialist advice. Hugh Phelan Solicitor can advise on international succession. Call 021-489-7134.
Do I need a separate will for my UK property?
Post-Brexit, UK property may require separate consideration. For significant UK holdings, a separate UK will may be advisable alongside your Irish will.
What is the EU Succession Regulation?
A European Union regulation allowing EU citizens to elect the law of their nationality to govern their entire estate across EU countries. An Irish citizen can elect Irish law for EU property in their Irish will.
Hugh Phelan Solicitor & Notary Public — Douglas, Cork
Wills · Probate · Enduring Power of Attorney · Notarisation & Apostille
📞 021-489-7134 Book Appointment →