Succession: Spain → UAE

Which law decides who gets what

The testator lives in an EU country (Spain). Under the common European rules the whole estate is governed by that country's law — wherever the assets are.

Who the law forces you to include

Spain: Legítima: ⅔ of the estate is reserved for children (⅓ strictly equal), with a usufruct over part for the spouse; regional variations apply.

A workable route: choose the applicable law in the will in advance and/or move assets into a structure (foundation, trust, holding) where shares are inherited rather than the assets themselves.

Where tax arises

Spain: Impuesto de Sucesiones — regional, rates up to ~34%, but large regional reliefs for close relatives.

How it is recognised and processed

Within the EU there is a single document — the European Certificate of Succession: it is recognised across all EU states, with no need to go through the procedure in each one.

Testator and heir in different countries — documents will need cross-jurisdiction recognition and legalisation (apostille, translation, sometimes a repeat procedure).

What to set up in advance

Will with a choice of applicable law

Trust

Private foundation

Insurance wrapper for assets

Part of the estate is reserved by Spain law for close relatives — it cannot be freely reallocated by will.