Support for executors/administrator of English estates in Germany
We advise and assist clients acting as executors or trustees of UK estates or trusts with assets in Germany and/or having German heirs. Our services include:
- Obtaining recognition of validity from German probate courts for English wills and the issuance of German Letters Testamentary (“Testamentsvollstreckerzeugnis”) for English executors
- Assistance with obtaining German Certificate of Heirship (“Erbschein”) for English heirs
- Providing legal representation for English heirs, beneficiaries, executors, administrators and trustees of estate) in connection with obtaining assets held by German banks, insurance companies and financial institutions, passing both through or outside of probate
- Assistance with the preparation and filing of German estate, inheritance, and gift tax returns for English estates, heirs and beneficiaries to ensure recognition of payments of English gift and estate taxes (federal and state) in Germany and deduction of such payments from any German estate, inheritance and gift tax liabilities
- Representing English executors, administrators, heirs, beneficiaries and trustees before German probate courts and taxation authorities, including obtaining tax clearance for the release of German assets passing to English heirs and beneficiaries and defending against claims of unwarranted German estate, inheritance and gift taxes
- Consulting regarding the structuring and timing of distributions from English trusts by English trustees to German resident beneficiaries to minimize any German estate, inheritance and gift tax liabilities
Upon request, we offer consultation via Zoom. For general information on how to join an instant meeting through an email invite, please visit the Zoom website.
News
- German Federal Civil Court: Application of English law can Violate German Public
- Cologne Court of Appeal: Application of English law can violate the German Public Policy
- German Federal Fiscal Court Ruling on Taxation of Distributions from a Foreign Family Foundation and a Foreign Trust
- FG Münster: Deed of Variation not recognized in Germany for Inheritance and Gift Tax Purposes
- UK: Draft Inheritance and Trustees’ Powers Bill
- Succession regulation published and will apply from 17 August 2015