Unilateral relief (Anrechnung)

Upon application a foreign death tax will be offset against the German inheritance tax (Erbschaftsteuer) if:

  • either the deceased or the beneficiary was a German tax resident (Inländer), 
  • estate assets are located outside of Germany, which are taxable in Germany and abroad,
  • the foreign tax is comparable to the German inheritance tax,
  • the foreign tax was assessed and paid,
  • the foreign tax accrued within the last 5 years prior to the German inheritance tax. See § 21 of the German inheritance and Gift Tax Act


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