Foreign Assets and Probate in Ireland — Cork Estates With Property Abroad

Many Cork families have relatives who owned property, bank accounts, or investments outside Ireland — whether in the UK, Spain, France, the USA, or elsewhere. When the deceased had foreign assets, probate becomes significantly more complex.

Irish Probate for Foreign Assets — The General Rule

An Irish Grant of Probate only has legal effect in Ireland. Foreign countries do not automatically recognise an Irish Grant. To administer foreign assets, you typically need either:

• A separate grant of probate (or equivalent) in the foreign country, or
• Re-sealing of the Irish grant in countries that accept it (mainly Commonwealth countries)

Property in England/Wales or Northern Ireland

Irish Grants of Probate are not automatically valid in England/Wales or Northern Ireland. However, they can be re-sealed by the Probate Registry in those jurisdictions, which is simpler than applying for an entirely new grant. A Cork solicitor coordinates this with an English solicitor.

Property in Europe (Spain, France, Portugal)

The EU Succession Regulation (Brussels IV) applies to deaths after August 2015. It generally means the law of the country where the deceased was habitually resident applies to their estate — not the law of the country where property is located. This can simplify EU cross-border estates but still requires local foreign procedures to transfer title to property.

Property in the USA or Other Non-EU Countries

These require separate probate or administration in each relevant state or country. A Cork solicitor who handles international estates coordinates with foreign lawyers to manage these processes.

Declaring Foreign Assets in Ireland

All worldwide assets of Irish-domiciled persons must be declared on the Irish CA24 Revenue affidavit. Foreign assets are valued in local currency and converted to euros. CAT applies on worldwide assets for Irish-domiciled beneficiaries.

Foreign Bank Accounts

Foreign bank accounts may be releasable on presentation of the Irish Grant of Probate (if the bank accepts it), or may require additional local process. Contact the foreign bank at an early stage to understand their requirements.

Tips for Cork Estates With Foreign Assets

• Instruct a Cork solicitor with international estate experience early
• Compile a complete list of all foreign assets and their locations
• Obtain foreign account statements and property valuations as soon as possible
• Allow additional time (and budget) for foreign procedures — they take longer and cost more
• If you have foreign assets, make wills in each relevant country for local assets