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deduct German inheritance tax

German ProbateGerman Tax Law

Deed of Variation and International Succession

Careful when using a Deed of Variation to mitigate UK Inheritance Tax! The Deed may backfire if there are foreign assets or beneficiaries who live outside the UK If someone dies intestate and leaves both a surviving spouse and a child (or children), then UK inheritance tax is due if the value of the estate exceeds GBP 900,000. In these cases, it is tempting to make use of a Deed of Variation in order to…
Bernhard Schmeilzl
November 9, 2016
German ProbateGerman Succession & Inheritance LawGerman Tax Law

Can foreign Taxes be set off against UK Inheritance Tax?

Unilateral Inheritance Tax Relief in British-German Probate Matters If a legator was domiciled (or legally deemed to be domiciled) in the UK and possessed assets in other countries, then HMRC will levy inheritance tax on the entire estate, i.e. all assets worldwide (see here). The problem is: Other jurisdictions may employ an entirely different inheritance tax system and also demand inheritance tax. Germany, for example, does not use domicile but citizenship (nationality) and residency to…
Bernhard Schmeilzl
July 4, 2014