Under the rules of the German Inheritance and Gift Tax Act, the worldwide transfer upon the death of an individual is subject to German inheritance tax if either the beneficiary or the deceased is a German tax resident (Inländer) at the time of his death. See § 2 of the German Inheritance and Gift Tax Act. This is generally referred to as unlimited tax liability (unbeschränkte Steuerpflicht). Please note that a Treaty may limit the right to tax assets that are generally subject to German unlimited inheritance tax tax liability.
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06/11/2022 German Federal Fiscal Court Ruling on Gift Tax triggered by Distributions from a Foreign Trust
06/11/2022 German Federal Fiscal Court: Assets titled in Trust to which the Grantor has reserved comprehensive Powers are to be considered owned by him for German Inheritance and Gift Tax Purposes
08/10/2021 Cologne Court of Appeal: Application of English law can violate the German Public Policy