Although under Portuguese civil law, the succession of foreign nationals is governed by their personal law, a number of countries do not accept such remittance and as a result, an inheritance may end up being subject to Portuguese succession law, which for families originating in “common law” countries, may end up as a shock.

Forced heirship laws will likely be applied to protect Portuguese spouses of foreign nationals, irrespective of their personal law if there are assets located in Portugal.

In the case of foreigners owning immovable property in Portugal it is wise to also have a local will to facilitate succession and local probate of the locally held property.