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Legal tip 1516.When UK Probate Needs Spanish Law: How an Expert Affidavit Unblocked a Grant
Friday, October 17, 2025

Published: October 2025 — Information valid at time of publication.

A UK executor came to us mid-process: the Probate Registry had paused their application with a one-liner—

“Please provide an affidavit explaining the relevant Spanish succession law.”

Classic cross-border snag. The deceased had ties to Spain, so the Registry needed clarity on which rules applied and what the executor could actually do with Spanish assets.

Snapshot

  • Problem: UK Probate Registry requested a Spanish-law affidavit.

  • Our work: Fact review (domicile, wills, assets) → expert affidavit under EU Succession Regulation 650/2012 covering legítimas (forced heirship) and executor powers → notarisation + apostille.

  • Outcome: Affidavit accepted; Grant of Probate issued without further queries.

How we solved it

1) Pin down the law that governs

We verified domicile/habitual residence, checked for UK and/or Spanish wills, and listed Spanish assets. With that, we confirmed the applicable law under Reg. 650/2012 and whether Spain’s forced-heirship rules affected the distribution.

2) Draft a clear, court-ready affidavit

We produced an English-language expert affidavit that:

  • Summarises the relevant provisions of Spanish succession law.

  • Explains who the heirs are under that law.

  • Sets out executor/administrator powers over Spanish property.

It was sworn before a notary and apostilled for UK use.

3) File, accept, move on

The executor filed the affidavit with the application. The Registry accepted it without follow-up, and the Grant issued—letting the estate move forward.

Why this matters

Cross-border estates don’t have to stall. A precise, credible Spanish-law affidavit translates the legal systems, reduces Registry back-and-forth, and protects timelines.

What we deliver

  • Expert affidavit under Reg. 650/2012 tailored to your facts.

  • Practical analysis of legítimas and any elective choices of law.

  • Clear mapping of executor powers for Spanish assets.

  • Notarisation and apostille arranged end-to-end.

FAQ

Will the UK Probate Registry accept it?
Yes—when drafted by a qualified Spanish-law expert, in English, properly notarised (and apostilled if sworn abroad).

How long does it take?
Typically a few days to two weeks once we have everything.

What documents do you need from me?

  • Copies of all wills (UK/Spain)

  • Evidence of domicile/habitual residence

  • Family details and marital property regime

  • List of Spanish assets (with basic title info)

  • The exact wording of the Registry’s request

Stuck on a “Spanish law affidavit” request?

We prepare Spanish-law affidavits for probate applications across England & Wales and Spain—clear, compliant, and designed for swift acceptance.

Contact us
Service areas: Spain · England & Wales

Author: María de Castro, Abogado (Spain)



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