If someone who owns assets in Germany dies, these foreign assets will only be released if a German (!) Grant of Probate can be presented. Since the UK has opted out of the EU Succession Regulation, an English Grant of Probate (or Scottish Confirmation) is worthless abroad, just as British financial institutions do not accept non-UK Grants. Thus, in principle, a national Grant of Probate must be obtained in each and every jurisdiction, where the testator held assets.
In Germany, the executors and beneficiaries have a choice between applying for a Certificate of Inheritance (Erbschein) or a Certificate of Executorship (Testamentsvollstreckerzeugnis). Details of which are explained here. Continue reading