International heirs

Cross-border inheritance issues, explained

What changes when the heirs, the deceased or the documents are outside Argentina.

Foreign heirs' rights

Foreign nationality or residence does not limit inheritance rights in Argentina. A foreign heir inherits on the same terms as an Argentine heir.

When the deceased lived outside Argentina

As a general rule, the succession is governed by the law of the deceased's last domicile and heard by the courts of that place. Argentine real estate is the main exception: Argentine courts are competent over it and Argentine law governs its succession, including forced heirship. In practice, a family may need proceedings in two countries, which should be coordinated.

Foreign death, birth and marriage certificates

Certificates issued abroad are accepted in Argentina once apostilled (or legalised) and, if not in Spanish, translated by an Argentine certified translator. Names that differ between documents, a common issue with immigrant families, may need additional proof.

Powers of attorney

Signed at an Argentine consulate or before a local notary with an apostille. Certain acts, such as selling real estate, require express powers. Read the guide.

Foreign wills

A will made abroad is generally valid in Argentina if its form complies with one of the laws Argentine law accepts. Over Argentine real estate, it must respect the reserved shares of forced heirs. Foreign wills.

Inherited property

Real estate is registered in the heirs' names or sold on the basis of the court's decision. Inherited real estate.

Bank accounts

Banks release balances on a court order. Foreign heirs may need an Argentine tax identification number and must consider the foreign-exchange rules in force. Bank accounts and financial assets.

International coordination

We work with the heirs' lawyers, executors, trustees and accountants abroad, and report in English.

Cross-border tax considerations

Argentina has no national inheritance tax, although the Province of Buenos Aires taxes free transfers of property. Selling inherited property has its own tax treatment in Argentina, and the inheritance and the sale may also have consequences in the heir's country of residence. We coordinate with tax advisers on both sides; we do not give tax advice on foreign law.

References: CCCN arts. 2643–2645; Hague Apostille Convention (1961); Province of Buenos Aires Law 14.044. To be verified before publication.

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