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Programme guides · Portugal Golden Visa (Fund Investment)

Trust Recognition in Civil-Law Countries

Written by Global Immigrate consultants · Reviewed by Oscar Yip, Founder & Managing Director

Summary

Limited recognition can complicate succession and tax characterisation.

Short answer: in civil-law countries that do not fully recognise trusts, legal characterisation, tax and succession of trust assets can be disputed. Before moving, assess local alternatives (e.g. foundations).

FAQ

Hague Trusts Convention?

Contracting states recognise more easily — others may not.

Immigration view?

Trust papers can explain source of funds — local property law is separate.

Unwind the trust?

Depends on destination and asset type — specialist assessment.

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