A simple guide to key terms used in cross-border estate planning
Understanding inheritance terminology can be challenging, particularly when dealing with assets in both the UK and Spain.
By Barry Davys
This article is published on: 1st April 2026

Understanding inheritance terminology can be challenging, particularly when dealing with assets in both the UK and Spain.
Differences in legal systems, tax rules, and administrative processes can cause confusion for individuals and families managing cross-border estates. This guide is designed for UK nationals living in Spain, Spanish residents with UK assets, and anyone involved in administering an estate that falls under both jurisdictions. It explains commonly used inheritance and probate terms in clear language to help you better understand the process and make informed decisions.
A written document prepared before a person’s death that sets out their instructions regarding who should manage the administrative aspects of their estate, who will be responsible for looking after their money and possessions while the process is being completed, and who they wish their assets to be distributed to.
The “estate” is the collective term for all financial interests of the deceased. This includes bank accounts, insurance policies, pensions, property, shares (including private and family-owned company shares), bonds, loans made to third parties that now need to be repaid, and other assets.
In Spain, rules apply regarding how two thirds of an estate must be distributed. Children take priority over spouses, and only one third of the estate can be freely distributed.
However, for expatriates living in Spain, EU Regulation 650/2012 (“Brussels IV”) allows them to elect for the inheritance laws of their nationality to apply to their Will. For a UK national, for example, this makes it possible to distribute the entire estate in accordance with their wishes.
Please note that this EU regulation only applies if the instruction is expressly included in the Will.
Probate is the term used to describe the legal process of administering and distributing an estate.
In Spain, the document confirming distribution in accordance with the law and the Will is called the Escritura de Aceptación y Adjudicación de Herencia (Deed of Acceptance and Adjudication of Inheritance), which must be signed before a Spanish notary.
In the UK, the equivalent document is known as the Grant of Probate, which is issued by the Probate Office.
A trustee and executor can be the same person, although it is often more than one individual in order to share the administrative responsibility.
The trustee is responsible for safeguarding the assets of the estate until they are formally transferred to the beneficiary. The executor is responsible for ensuring the legal formalities are completed so that the transfer of assets to the beneficiary is valid.
A beneficiary is a person named in the Will who will receive all or part of the estate.
A bequest is the term used to describe what is transferred to a beneficiary. This may consist of a single asset, such as a property, or multiple assets, such as property, bank account balances, and shares. A group of assets transferred together may also be referred to as a bequest.
Modelo 650 is the Spanish tax form used to declare and pay inheritance tax and to support the preparation of the Escritura de Aceptación y Adjudicación de Herencia.
The UK form used to apply for a Grant of Probate is Form PA1P (if there is a Will) or PA1A (if there is no Will).
If inheritance tax is due, the executor must first complete Form IHT400.
In the UK, the estate of the deceased is assessed for inheritance tax. The assessment is based on the total value of the estate.
In Spain, each beneficiary who is a Spanish tax resident is assessed individually for inheritance tax based on the value of the assets they receive.
As the UK and Spain tax different entities (the estate in the UK and the beneficiary in Spain), the same entity is not taxed twice. As a result, inheritance tax is generally outside the scope of the Double Taxation Agreement.
However, practical solutions may be available depending on individual circumstances, and appropriate professional advice should be obtained.
Inheritance tax is generally due within six months of the date of death. It is important to note that tax is not due from the date the beneficiary physically receives their bequest, which is a common misconception.
This six-month rule applies in both Spain and the UK:
At the start of every client relationship, we carry out a detailed discovery process to fully understand your personal and financial circumstances.
In this case, a married couple, both UK nationals living in Spain, held life insurance policies valued at £1,000,000 each. During our review, we identified that the appropriate Inheritance Tax mitigation documentation had not been put in place. Without this structure, the value of the life insurance policies would form part of their estate and could be subject to UK Inheritance Tax for their UK tax-resident beneficiaries.
Given that their estate exceeded the available allowances, this created a potential Inheritance Tax liability on the life assurance proceeds.
We implemented the appropriate documentation to ensure the policies were structured correctly. As a result, up to £400,000 per policy (£1,000,000 × 40%) in potential Inheritance Tax is avoided for their beneficiaries.
This article is provided for information purposes only and does not constitute legal advice. We recommend seeking professional legal advice to assist with the probate and distribution processes of an estate.
A specialist Inheritance Tax and Wills lawyer works with us to provide this service.
For an introduction to the lawyer, please email:barry.davys@spectrum-ifa.com
By Barry Davys
This article is published on: 19th March 2026

A common question from people living in Catalonia is about Wealth Tax; What assets are Wealth Tax based on, how it is calculated, how can we manage the amount we have to pay, when is it due and what forms are needed for Wealth Tax. This article gives insight into the answers to these questions.
Wealth Tax in Catalonia is assessed annually on our Worldwide assets but less liabilities Eg mortgages.
Each individual is given an allowance of €500,000 before tax is assessed. In addition, there is an allowance for owners of their main residence of upto €300,000. If your share of the house is €250,000 you can only claim €250,000 as the allowance. If your share of the house is €450,000, you will be given an allowance of €300,000 and the balance will be added to the rest of your wealth to be taxed.
Over and above these allowances, tax is calculated in a series of levels. These levels start from the first euro above the allowances given in the answer above. For example, if your wealth is €667,129.45 and you do not have a main residence, from the table below the tax will be €350.97. (667,129.45 -€500,000 = 167,129.45)
| Net tax base Up to euros | Tax payable Euros | Remainder of tax base Up to euros | Applicable rate Percentage |
| 0.00 | 0.00 | 167,129.45 | 0.210 |
| 167,129.45 | 350.97 | 167,123.43 | 0.315 |
| 334,252.88 | 877.41 | 334,246.87 | 0.525 |
| 668,499.75 | 2,632.21 | 668,500.00 | 0.945 |
| 1,336,999.75 | 8,949.54 | 1,336,999.26 | 1,365 |
| 2,673,999.01 | 27,199.58 | 2,673,999.02 | 1,785 |
| 5,347,998.03 | 74,930.46 | 5,347,998.03 | 2,205 |
| 10,695,996.06 | 192,853.82 | 9,304,003.94 | 2,750 |
| 20,000,000.00 | 448,713.93 | upwards | 3,480 |
The amount we pay is based on the assets listed above. However, to avoid our total tax liability leaving us with little or no income, a “tax shield” (Escudo fiscal sobre el patrimonio) has been put in place. This shield is based upon a set formula
A way, therefore, to manage our Wealth tax liability is to plan our income and our asset purchases.
The assessment for Wealth Tax is a section within our La Renta annual tax return. The proper name of the form is Modello 100. This is the form you are likely already completing for your income tax and savings tax. Be sure to provide your tax lawyer with the values of assets that may be assessed for Wealth Tax so they can be included on La Renta. This form must be submitted by the 30th June at the latest, whilst La Renta’s can be submitted as early as April.
An important point to note is that all the taxes arising from the La Renta have to be paid by the 30th June. This means any income tax, capital gains tax and Wealth tax have to be paid together.
By Barry Davys
This article is published on: 17th December 2025

The Intra-Company Transfer (ICT) Visa is designed for non-EU employees of multinational companies who are being temporarily transferred to a branch, subsidiary, or client in Spain. It is intended for managerial, technical, or highly specialised staff.

Obtaining your visa is a crucial step, but understanding the financial implications of your relocation is just as important.
Many ICT applicants ask whether they can access the Beckham Law and how this could affect their tax position. While the widely advertised 24% tax rate on earnings up to €600,000 per year is the most visible element, there is another significant benefit that can greatly reduce your tax bill for the entire five-year period of the regime.
At The Spectrum IFA Group, our advisers combine professional expertise with first-hand experience, having each gone through the relocation process themselves. We help clients optimise their finances and make informed decisions before and after moving to Spain.
While we specialise in financial planning, we are not immigration lawyers. For visa matters, we work closely with Klev & Vera, a respected Barcelona-based law firm led by managing partner Anna Klevtsova, who holds degrees in International Law from both the UK and Spain.
This collaboration ensures clients receive:
For full transparency: we do not accept commissions or referral fees from these lawyers. Our priority is that clients receive accurate, high-quality advice.
By Barry Davys
This article is published on: 10th December 2025

The Highly Qualified Professional Visa is designed for non-EU professionals with specialist skills who have been recruited to work in Spain, particularly in high-demand sectors such as technology, engineering, and research.

Securing your visa is a major milestone — but it’s equally important to understand how relocating to Spain will affect your finances.
Many applicants ask whether they can join the Beckham Law while on the HQP Visa, and what this could mean for their tax position. While the well-known 24% tax rate on employment income up to €600,000 is widely published, there is another significant benefit that can substantially reduce your tax bill for the entire five-year duration of the scheme.
At The Spectrum IFA Group, our advisers are both professionally qualified and personally experienced in moving to and living in Spain. We help clients understand how to structure their finances efficiently from day one.
HQP Visa not suitable? View other visa options for British nationals.

While we are experts in financial planning, we are not visa specialists. For immigration matters, we work closely with Klev & Vera, a Barcelona-based law firm led by managing partner Anna Klevtsova, who holds degrees in International Law from both the UK and Spain.
Our collaboration ensures clients receive clarity on:
For transparency: we do not receive any commission or fees from these lawyers. Our priority is that clients receive accurate, reputable advice.
You may be able to reduce your tax burden by opting to be taxed under the special non-resident tax regime (Beckham Law) if you meet the following conditions:
You may qualify for the regime under any of the following employment structures:
Each pathway has specific requirements, so professional tax advice is essential to confirm eligibility before relocating. We work with specialist tax lawyers who can assess your circumstances — and again, we do not receive any form of commission for referring clients.
By Barry Davys
This article is published on: 8th December 2025

A residence permit for non-EU remote workers and freelancers who wish to live in Spain while working for companies outside the country.

Your Visa is an important step for your move to Spain. At the same time, it is very important to have an understanding of how your finances will be affected when you move to Spain. For example, can you join the Beckham Law on the Digital Nomad Visa? What will this mean for your financial position? Whilst the 24% tax rate on earnings up to €600,000 pa is the most posted part of the rule on the internet, there is another very important benefit. This second benefit can hugely reduce your tax bill when moving to Spain and for the whole five tax years you are on the scheme,
At The Spectrum IFA Group in Spain, we are familiar with these opportunities both from our professional knowledge and our own experience of all our advisers having made the same move and who now live in Spain.
Case Study, How we helped a Spanish Tax Resident Couple after they moved to Spain
Why a financial adviser is essential for expats living in Spain
The DNV not suitable for you? See all the other available Visas for Spain for British nationals here
Whilst we are experts in our own field, we readily admit we are not experts in Visas. We, therefore, work with Visa lawyers at Klev & Vera, based in Barcelona. The firm is led by managing partner Anna Klevtsova with whom we have worked with for a number of years. Anna has a degree in International Law from the UK and a Masters degree in International Law in Spain.
The result has been clarity for clients moving to Spain on what type of visa is right for them, help with applying for the visa and availability to deal with ongoing matters such as the Spanish state pension.
By Barry Davys
This article is published on: 2nd December 2025

A long-term residence permit for non-EU citizens who wish to live in Spain without working.
Popular with retirees and financially independent individuals seeking a new lifestyle in Spain.

Also needed is an understanding of how your finances will be affected when you move to Spain. At The Spectrum IFA Group in Spain, we are familiar with these changes both from our professional knowledge and our own experience of all our advisers having made the same move and who now live in Spain.
The Spectrum IFA Group in Spain assists individuals, employees and families moving to Spain with all financial aspects of their move. It starts with what actions are beneficial to take before you come to Spain and what needs to wait until you are resident in Spain. From the vital planning, how to save when in Spain, how to manage your tax on your savings, pensions in Spain and even, how to best manage currency transfers from the UK to Spain.
By Barry Davys
This article is published on: 24th November 2025

What you need to know
On 26th November 2025, the Chancellor of the Exchequer, Ms. Rachel Reeves, will present the Autumn Budget to the House of Commons. While some minor changes, like an increase in taxes on spirits, might take effect immediately; most changes won’t be implemented until later.
Despite this, the media will extensively cover the Chancellor’s statement on the day, often without clarifying that the proposed changes won’t take effect right away. You’ll likely see numerous articles, podcasts, webinars, and briefings discussing the Budget, based on the announcements made in Parliament. However, it’s important to be cautious before acting on these updates.
The UK Parliamentary Commons Library defines the Budget as follows:
“The Budget is a statement made by the Chancellor to MPs in the House of Commons, presenting the government’s plans for the economy, including changes to taxation and spending.”
This is key because the Budget is just a statement of intent – not a law yet. Before any proposed changes become law, they go through several stages:
This process means that the initial announcements made in the Budget are still subject to change before they are finalized.

If the Budget includes a tax rise on whisky or similar immediate changes, it’s fine to take action before the increase goes into effect. However, for more complex changes (like pension reforms, stamp duty adjustments, income tax rates, and changes to ISAs), it’s wise to wait until the Finance Bill 2025 becomes law.
It’s important to remember that the Budget announcements are only the starting point. During the parliamentary readings of the Bill, amendments can be made—sometimes significant ones. In fact, in 2025, the media suggests there could be notable opposition from even the government’s own MPs, meaning the final law may differ substantially from the initial Budget statement.
Making financial decisions based on the Budget before the Bill is passed into law could lead to costly mistakes that impact your finances for years to come.
To avoid acting on speculation, it’s best to let the media buzz die down after the Budget. The real, final changes will become clear in the Finance Act 2025, at which point you can make decisions based on confirmed facts.
If you’re living in or moving to Spain, and want advice on how the 2025 UK Budget might impact your finances, feel free to book a consultation at a time that works for you using our online booking system.”
By Barry Davys
This article is published on: 19th August 2025

Husband 60, wife 60, married, with two children who are financially independent and living in the UK
a) Completed a full financial review of present financial standing
b) Undertook a cash-flow forecast to establish if widow’s pension was sufficient, how to pay inheritance tax on first death and how long their money would last
c) Consolidated pensions to improve tax efficiency, improve widow’s pension and manage in line with their other assets
d) Built investment strategy to improve return on their investments and cash
e) Clarified how inheritance tax applies in Spain and UK and gave an estimate of tax due
f) Built an inheritance tax strategy, including provision for sufficient funds to pay tax in Spain on first death
g) Minimised Spanish tax paperwork and liaised with Spanish tax adviser
h) Produced a family inheritance tax strategy document so whole family knew the strategy without disclosing amounts held by the parents
i) Wrote to UK HMRC to obtain confirmation that the family home in Spain would qualify for the Main Residence Nil Rate Band
j) Identified UK inheritance tax saving on a UK life assurance policy
k) Carried out regular reviews over 12 years (so far) to update investment and inheritance tax strategies and to adapt to legislative changes
If you are resident in Spain, or are planning to move here, and would like to receive information on tax-efficient investing, pension transfers, investment planning or general financial planning, you can contact me on: barry.davys@spectrum-ifa.com or direct on 0034 645 257 525 – The Spectrum IFA Group (Spain)
By Barry Davys
This article is published on: 30th June 2025

It is all about the planning, solutions, implementation and continuing support (PSIC).
We take as long as is necessary to understand your situation and listen to your hopes and plans for the future. It is time well spent because to be effective for you, we work to understand first, which then guides the process for your planning. In fact it governs how you and your adviser approach each step in our PSIC process..
How did our mortgage broker source a mortgage for a High Net Worth person who had become a tax resident in Spain wanted a mortgage as part of his strategic financial planning to improve his capital efficiency.”
Find out how here.
– 31 over €1M
– 13 over €2M
– 7 over €3M
– 3 over €4M
– 1 over €5M
– 1 over €6M
– 2 over €7M
– 1 over €8M
– 6 with Price by Request

If this is how you want your planning to be managed, book an initial call directly with Barry Davys, at a time that is convenient for you, using his online service. You will be offered the choice of a phone call or a video call when choosing your time.
By Barry Davys
This article is published on: 27th June 2025

Are you planning to relocate to Spain and don’t know where to start? Are you a Spanish national thinking of coming back to Spain after more than 5 years in the UK?
Barry Davys was a guest with the Spanish Chamber of Commerce alongside Kle&Vera – the international law firm, in the UK for a recent webinar on Relocating to Spain & the Financial Insights.
You can watch part of this webinar below:
If you have any questions after watching the video or would like to talk to Barry, please use the online calendar booking system to choose a time that suits you.