It is the most repeated conversation in cross-border probate: the executor, foreign grant in hand, presents it to an Irish bank or the Land Registry and hears the same answer — “we need an Irish grant.” Not a translation of the foreign one, not a stamp on it: a fresh grant, extracted in Ireland, under Irish rules. This article explains why, what the foreign grant is still worth, and the sequence that gets the Irish grant out with the least lost time.
No Resealing — the Uniform Irish Rule
Resealing — the Commonwealth shortcut by which one jurisdiction stamps another’s grant into local effect — does not operate in Ireland: no foreign grant, from the UK, the US, Australia or anywhere else, has direct authority over Irish assets. Where the Irish holdings exceed the working release thresholds (roughly €20,000, and always for Irish land), the estate’s Irish limb runs through the Irish Probate Office as a full application — its own Revenue SA.2, its own entitlement rules, its own queue. The rule is strict but even-handed, and its practical meaning is simple: the Irish grant should be planned from the start of the estate, not discovered at the end of it.
What the Foreign Grant Is Still Good For
The home-country grant is the Irish application’s best exhibit: a court-sealed certified copy evidences the will, the death, the domicile — and, decisively, who the home court entrusted with the administration, which under the Irish rules for foreign-domicile estates usually identifies the person entitled to the Irish grant. Around it assemble the rest of the bundle: certified translations for foreign-language documents, papers sworn before notaries abroad, and the asset schedule with date-of-death values. The analytical step that shapes everything sits underneath: Irish land answers to Irish succession law whatever the domicile; movables generally follow the domicile — a split that decides who takes what, and occasionally reveals that Irish statutory rights touch the Irish property in ways the home-country will never anticipated. Where that discovery turns contentious, the practice’s litigation half is behind the same door.
The Sequence That Works
Run the Irish limb in parallel, not in series: the sealed foreign-grant copy ordered the week the home grant issues; PPS-number applications for non-resident parties started day one (the commonest bottleneck — the non-resident executor’s guide covers it); translations and notarised documents moving while values are gathered; and the application lodged through eProbate with every name and detail consistent, because rejection costs the queue place. Done this way, the Irish office’s own processing — now weeks for clean files — stops being the story. The full speciality, including the foreign-lawyer agency service and the who-does-what of tax (routed to the accountants, always), lives on the international probate page.
Frequently Asked Questions
Foreign Grant, Irish Assets?
Send the sealed grant copy, the death certificate and the Irish asset list - the reply maps entitlement, documents, timeline and costs before any commitment. Run in parallel, the Irish limb lands in months, not years.
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About the Author
Richard O’Shea, Solicitor, TEP practises with Mary Molloy Solicitors (established 1981) in probate, will disputes and estate litigation throughout Ireland. Richard is a qualified Trust and Estate Practitioner (STEP) — the international specialist credential for wills, trusts and estates — and holds a Diploma in Mediation from the Law Society of Ireland, a pairing built for exactly this work: specialist estates expertise, and the means to keep families out of war where that is still possible. Contact Richard on 01 5827148 or richardoshea@marymolloysolicitors.com.
This article is for general information only and does not constitute legal advice. Every estate and family situation is different, and time limits in this area are strictly applied - obtain advice on your own circumstances before acting or deciding not to act. We do not advise on tax; taxation questions should be directed to your accountant and Revenue’s published guidance. In contentious business, a solicitor may not calculate fees or other charges as a percentage or proportion of any award or settlement.