Inheritance & Succession in Germany

How German Succession Law Affects U.S. Owners and Heirs

German property, bank accounts or investments can bring part of your estate under German law, even if you live in the United States. Germany applies the EU Succession Regulation, under which the law of a person's habitual residence generally governs the succession unless that person has chosen the law of their nationality. German law also gives close relatives a compulsory-portion claim against the estate (Pflichtteil), and heirs often need a certificate of inheritance (Erbschein) from a German court to deal with banks and registries. German inheritance and gift tax (Erbschaftsteuer) may apply to assets in Germany.

Our German Succession and Cross-Border Estate Services

• Obtaining the Erbschein for heirs, handling German inheritance tax (Erbschaftsteuer) filings and coordinating with German courts.
• Explaining forced-heirship rights (Pflichtteil) and preparing German-valid wills alongside U.S.-compliant estate documents.
• Advising on the EU Succession Regulation (Brussels IV) and whether German or foreign law applies to the estate.
• Coordinating German–English estate translations, asset transfers between Germany and the United States, and tax planning for non-residents.

Frequently Asked Questions About Property and Inheritance in Germany

Which country's law applies to my German property?

That depends on where you live and whether you have chosen the law that will govern your estate. Under the EU Succession Regulation the default is generally the law of your habitual residence at death, but you can often choose the law of your nationality. We review your situation and explain your options.

How do heirs prove their right to German assets?

German banks and property registries commonly ask for a certificate of inheritance (Erbschein) or an equivalent document. We help heirs understand what is required and coordinate the application with German professionals.

Do I need a German will in addition to my U.S. will?

Many owners of German property find it useful to have a will that works in Germany and is coordinated with their U.S. documents, so the two do not conflict. Whether you need one depends on your assets and your family.

Related Resources

• International estates and inheritance
• Cross-border inheritance planning: choosing the right law for your estate
• Other country guides: Spain, Portugal, Italy and France

Contact us today for a free initial consultation on your European estate or cross-border succession matter. Our bilingual team and international network help ensure a smooth transition for your estate across the U.S. and Europe.

This page is general information, not legal advice. Foreign law changes, and every estate is different.