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An English Lawyer and a Spanish Lawyer discuss effective succession planning when two different jurisdictions are involved.
An English lawyer has a client who owns property in Spain and seeks legal advice on succession. They ask a Spanish lawyer a series of questions to understand how to structure their client’s estate efficiently.
Our speakers discuss Article 22 of the EU Succession Regulation, how domicile and residency play a crucial role in determining inheritance tax liabilities and how inheritance tax is handled in Spain compared to England.
They also explore statutory legacies in Spain and what the options are when drafting a will, whether the client should have one will or separate wills for Spain and England, and what information should be retained to assist with probate in both jurisdictions.
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