unlimited tax liability (unbeschränkte Steuerpflicht)

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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