Is LEGAL TRANSLATION truly a “world apart”?

The core complexity arises when translating between an Anglo-Saxon (Common Law) system and a Roman-based (Civil Law) system.

Why?

For the simple reason that their legal foundations are fundamentally distinct.

When translating an English Commercial Law text, we need to look at two official sources: the Companies Act 2006 (UK) and the Código das Sociedades Comerciais (Portugal).

The goal is to identify equivalences between the two languages.

As Pedro Coral Costa notes, when direct equivalence is lacking, it requires deep cultural and legal systemic understanding, prioritizing “functional equivalence” while respecting both source and target cultures.

With the rise of international trade and global companies, the need for corporate document translation (often English to Portuguese) is soaring.

However, this field demands a highly specialized skill set and presents unique challenges:

> Expertise in both Portuguese legislation and Common Law systems is non-negotiable.
> Pre-translation work and post-translation review by legal experts are essential.

These projects require considerable time investment, and the consequences of even a minor error can be severe.

As Gurumac (2011) wisely stated, “Law is created by and for a society… reflecting the history, evolution, and culture of this same system.”

This underscores perfectly why legal translation is so much more than just words on a page.

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