Inheritance in Russia for Heirs Living Abroad

The fact that an heir lives in another country does not by itself change the place where the inheritance is opened in Russia. The key factor is generally the deceased's last place of residence, rather than the heir's place of residence. If the deceased permanently lived in Russia, the inheritance proceedings are normally opened at the deceased's last place of residence. The heir may at the same time live in any other country.

The situation is more complicated if the deceased also lived abroad. If the deceased's last place of residence was outside Russia but assets remain in Russia, the place where the inheritance is opened must be determined separately.

Article 1115 of the Russian Civil Code contains special rules for such cases. Where the deceased's last place of residence was abroad but assets remain in Russia, the place of opening the inheritance in Russia may be determined by the location of the Russian real estate, or its most valuable part, and if there is no real estate, by the location of movable property or its most valuable part.

In one 2026 case, the deceased had lived in Canada but left an apartment in Moscow. The Russian notary considered the available documents insufficient to establish the place of opening the inheritance conclusively and advised the heir to apply to court. The court established the place of opening the inheritance by reference to the location of the Moscow apartment.

If the deceased lived abroad and assets remain in Russia, the case may require a separate analysis. This situation is covered in my separate page “Inheritance in Russia When the Deceased Lived Abroad.”

Yes. In many cases, an heir does not need to come to Russia personally in order to accept an inheritance. An application to accept the inheritance can be executed abroad and sent to a Russian notary. Depending on the country, the heir's signature may be certified by a foreign notary or by a Russian consular officer. If the document is notarised abroad, it is important to check whether an apostille or consular legalisation is required, or whether an international treaty removes these formalities.

Russian case law confirms that this procedure can be used. In one case, an heir lived in Germany. Within the six-month deadline, she signed an application to accept the inheritance before a German notary, obtained an apostille and sent the document to the Russian notary in Volgograd. The court held that the inheritance had been accepted in time even though the heir was physically in Germany.

When I handle an inheritance matter, I determine in advance which documents the heir needs to sign abroad, prepare them in a form suitable for the Russian procedure, review them after execution and organise their further use in Russia.

In many cases, a substantial part of the inheritance procedure can be handled by a representative in Russia. This requires a power of attorney containing the powers needed for the particular estate.

The representative communicates with the notary, files the necessary applications, obtains certificates of inheritance, requests documents from civil registry offices and archives, deals with banks, the Federal Tax Service, Rosreestr and other authorities, registers title to inherited property and obtains the registration documents.

The power of attorney may also authorise the representative to receive money, obtain duplicate documents, manage inherited property, enter into an agreement on the division of the estate and represent the heir in court if necessary. A power of attorney can be executed at a Russian consulate or before a foreign notary. Russian courts have considered, for example, a power of attorney certified by a German notary, apostilled and translated into Russian, and accepted the possibility of using such a document in Russian inheritance proceedings.

When I handle the matter, I prepare the power of attorney for the specific estate and identify the necessary powers in advance. This helps avoid a situation where the heir has already visited a notary abroad, obtained an apostille and sent the document to Russia, only to discover that the power of attorney does not cover a required step.

A Russian notary can use documents issued by competent authorities of another country. For example, if a person died outside Russia, the death may be evidenced by a document issued in accordance with the law of the country where the death occurred.

Before such a document can be used in Russia, the applicable recognition requirements must be checked. Depending on the country, an apostille or consular legalisation may be required. If Russia and the relevant country are parties to a treaty removing these formalities, neither an apostille nor legalisation may be necessary.

Foreign documents normally also need to be translated into Russian and the translation properly certified.

In practice, the main difficulty is often not the validity of the document itself, but whether the documents taken together clearly establish the identity of the deceased or the heir and the relevant family relationship.

A person's name may appear differently in documents issued in different countries or at different stages of their life. This is particularly common where a person has several middle names, uses a shortened form of a name, has different transliterations or changed their surname after marriage. In such cases, it may not be enough simply to present each document separately. A chain of evidence may be required to demonstrate that the different versions of the name refer to the same person.

Foreign birth certificates, marriage certificates and other civil status documents are not always structured in the same way as Russian documents. For example, it may not be immediately clear from a foreign birth certificate which entry identifies the father, which identifies the mother, or what legal meaning a particular field has.

In these situations, additional documents or explanations from the competent authorities of the relevant country may be required. In one of my cases, for example, we obtained an explanation from a consulate so that the Russian notary could understand the contents of a foreign birth certificate and the family relationship it established.

For this reason, foreign documents are best reviewed before they are apostilled, translated and sent to Russia. When I handle the matter, I compare the documents in advance, discuss any problematic points with the Russian notary and determine what additional evidence may be required.

Missing the six-month deadline does not always mean that the inheritance has been lost. Depending on the circumstances, there may be three possible routes: establishing that the inheritance was actually accepted, obtaining the consent of the heirs who accepted the inheritance in time, or applying to court to restore the deadline.

An inheritance can be accepted not only by filing an application with a notary. Russian law also recognises actions showing that the heir treated the inherited property as their own. These may include paying expenses relating to the property, paying utility bills, taking measures to preserve the property, paying debts of the deceased or taking other steps in relation to the estate.

Such actions may be taken not only personally by the heir but also by other people acting on the heir's instructions.

In one of my cases, the heir had missed the six-month deadline for approaching the notary. However, during that six-month period, utility bills for the inherited apartment had been paid on the heir's instructions. We were able to prove both the payments and the fact that they had been made on behalf of the heir. The notary accepted that the inheritance had been actually accepted and issued a certificate of inheritance without court proceedings.

For this reason, before starting court proceedings, I first check whether the heir, personally or through others, took any actions in relation to the inherited property. Sometimes this is sufficient to complete the inheritance through a notary.

Yes. Article 1155(2) of the Russian Civil Code provides an out-of-court mechanism where the other heirs have already accepted the inheritance and agree that the late heir should also be included. In this situation, the reasons for missing the deadline do not have to be proved in court. The written consent of all heirs who accepted the inheritance must be properly executed.

If certificates of inheritance have already been issued, the notarial procedure allows new documents to be issued taking the additional heir into account. Where there is no dispute within the family, this may be considerably quicker and simpler than court proceedings.

If there is no evidence of actual acceptance and the consent of the other heirs cannot be obtained, it is necessary to assess whether there are grounds for restoring the deadline under Article 1155 of the Russian Civil Code. Living abroad by itself is not enough.

Once the certificate of inheritance has been issued, the heir's title to Russian real estate must be registered in accordance with Russian law. If the heir lives abroad, this process can also be handled through a representative. The representative obtains the necessary documents, deals with the notary and Rosreestr and handles registration of title. The relevant powers should be included in the power of attorney in advance.

As a result, in many cases an heir can register ownership of an apartment or other real estate without travelling to Russia merely to file or collect documents. If the estate includes land and the heir is a foreign citizen, I also check whether any special restrictions apply depending on the category and location of the land.

Funds held in bank accounts and deposits form part of the estate. The Russian notary establishes the composition of the estate and, once the necessary procedure has been completed, issues a certificate of inheritance.

A representative may communicate with banks and obtain the necessary information and documents. If the power of attorney contains the appropriate authority, the representative may also receive money due to the heir.

Receiving inherited funds from a Russian bank and transferring those funds to the heir's country of residence are, however, two separate stages.

The possibility of an international transfer must be considered separately in light of the particular bank, the destination country and the rules in force at the relevant time.

Receiving the inheritance is not always the client's final objective. A person who permanently lives abroad may have no intention of using an apartment in Russia and may wish to sell it after the inheritance has been completed.

A substantial part of this process can also be handled through a representative. However, the authority to deal with the inheritance and the authority to sell real estate are better treated separately and drafted in light of the client's specific plans.

The tax consequences and the heir's tax status should also be considered before the sale. For this reason, it is often better to discuss the future of the inherited property while the inheritance proceedings are still ongoing, rather than only after the certificate of inheritance has been issued.

In many inheritance matters, a personal visit to Russia is not required. Usually, the heir needs to sign the application to accept the inheritance and a power of attorney, provide identity and family relationship documents and, where necessary, obtain documents in the country where they live. The Russian part of the procedure can then be handled by a representative.

Whether a personal visit is necessary in a particular case depends on the assets, the available documents, the powers granted to the representative and whether there is a dispute. I assess this at the outset so that the client understands from the beginning which steps can be completed remotely.

If you live abroad and need to deal with an inheritance in Russia, an initial assessment usually requires basic information about who died and when, where the deceased lived, what assets remain in Russia, when you learned of the death, whether there are other heirs or a will and what documents you already have.

After reviewing the situation, I can determine whether an application to accept the inheritance must be filed urgently, which documents need to be executed abroad, whether a power of attorney is required and whether the Russian part of the procedure can be handled without your travelling to Russia.

I begin by reviewing the entire inheritance situation: where the deceased lived, when the death occurred, what assets remain in Russia, who the heirs are, what documents are already available, whether the six-month deadline has expired and whether an inheritance file has already been opened.

I then determine which Russian notary should handle the matter, communicate with the notary on any difficult issues, prepare the application and power of attorney for execution abroad, review foreign documents, obtain the necessary documents in Russia and deal with banks, civil registry offices, archives, the Federal Tax Service and Rosreestr.

If there is an issue with a missed deadline, I first consider whether actual acceptance can be established or whether the matter can be resolved out of court with the other heirs. If court proceedings are necessary, I represent the heir before the Russian courts.

This material does not constitute legal advice and is published for informational purposes only.