Inheritance abroad: a case that needed documents from three countries at once

Our clients' father spent his last years in Spain and died there. The flat remained in Moscow, bank accounts in Russia and Spain. One son lives in Germany, the other in Russia. The estate was opened, and the Russian notary issued a list of documents. Almost all of them turned out to be foreign.

Documents from Spain

The death certificate is issued by the Spanish civil registry. For Russia it needs a Spanish apostille and a notarised translation into Russian. Spanish registries also issue multilingual international extracts, but the Russian notary will still ask for a translation. If there is property in Spain, the Spanish notary will request a certificate from the registry of last wills.

Documents from Germany

The son living in Germany cannot come to the notary in Moscow. He makes a statement of acceptance of inheritance or a power of attorney before a German notary or a Russian consul. If made before a German notary, the document is apostilled in Germany and translated into Russian. The consular route is simpler: the document is in Russian from the start and needs no apostille.

Documents from Russia

The heirs' birth certificates (proof of kinship), title documents for the flat, information on accounts. If part of the estate is in Spain, Russian documents must be apostilled and translated into Spanish for the Spanish notary.

How not to get lost

We made a table: document — country of issue — where it is filed — apostille needed — target language. It came to 11 rows. We closed the Russian estate first: the apostilled Spanish death certificate was translated into Russian, and the son in Germany gave a power of attorney through the consulate. Then we prepared the file for Spain.

Tip: in an international inheritance, first establish where the estate is opened and which countries are involved, then ask each notary for their own list. And watch the deadlines: accepting an inheritance in Russia takes six months from the date of death, and international correspondence barely fits into that.