UK Citizens with Property in Germany: Do I need a separate Will?

The Basics of British-German Inheritance Cases

When a British expat lives in Germany for some time, he or she will most probably have a German bank account and other German assets, maybe even have bought property over here. The majority of these British expats have never thought about the inheritance law implications of such foreign assets. They simply assume that UK law applies. This is, however, not always the case. Especially if German probate law and the German inheritance tax office consider the UK citizen to have been domiciled in Germany, then German law applies to the entire (global!) estate. But even if a UK citizen never sets foot on German soil but only invests here, i.e. buys property or company shares, then he / she may be in for some surprises. Or to be precise: their heirs might be.

Let us try to explain the basics of this rather complicated matter of British-German inheritance law cases, using the example of the hypothetical couple Mr and Mrs Liveabroad: Continue reading

German Inheritance Tax Rates and Personal Tax Exempt Amounts

What is the German IHT Nil-Rate Band?

German inheritance law, including inheritance tax law, works very differently from the UK system (for German probate see here and here). While in the UK the estate as such is taxed (with one single nil-rate band of currently 325k GBP being available as tax relief) you find a completely different inheritance tax concept in Germany: Continue reading

Disinherit your no-good children? Not so easy in Germany

According to German inheritance law, close relatives have a right to claim a portion of the estate, even if the testator did not want to leave them anything and has consequently disinherited them. This so called “Pflichtteil” is mostly translated with “statutory share“, “forced share” or “compulsory share“. However, it is difficult to find the correct English word, because this concept does not quite exist in the English or US common law systems. And even to many German heirs this concept comes as a surprise.

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