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German property requires an Erbschein from the German Nachlassgericht, German inheritance tax returns, and German Land Registry registration. The Pflichtteil gives forced heirs a cash claim equal to half their intestacy entitlement — not a right to specific assets.
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Germany is home to significant British interests — business assets, investment property, and residential property held by expats. Germany's succession law is distinctive in that forced heirship (Pflichtteil) takes the form of a monetary claim rather than a right to specific assets, which can create cash flow issues for estates without liquid assets.
This guide explains the Pflichtteil, the Erbschein process, German inheritance tax, the Brussels IV election, the UK–Germany treaty, and practical steps for executors.
Germany applies Brussels IV. For UK citizens habitually resident in the UK at death, a Brussels IV election of UK law in the will can direct that UK succession law governs the German estate. Without such an election, the German courts may apply German law to German assets under traditional lex situs principles.
For a full explanation, see our EU Succession Regulation guide.
German law gives certain close relatives a Pflichtteil (compulsory portion). Critically, the Pflichtteil is not a right to inherit specific assets or a share in the estate property — it is a purely monetary claim against the estate equal to half the intestacy entitlement.
Who has a Pflichtteil claim:
Example: if a child would have inherited one quarter of the estate on intestacy but is excluded by will, they have a Pflichtteil claim for one eighth of the estate value (half of one quarter). This claim must be paid in cash by the estate within 3 years of the request (statute of limitations).
A Brussels IV election of UK law may disapply the Pflichtteil to the German assets if accepted by German courts. However, German courts retain discretion in some cases, and legal advice should be taken.
To deal with German banks, the Land Registry (Grundbuch), and other German institutions, the executor will usually need an Erbschein — a certificate of inheritance issued by the German Nachlassgericht (probate court, part of the local Amtsgericht).
Alternatively, if the deceased left a notarial will or a notarial Erbvertrag (inheritance contract), the notarial document together with the death certificate may suffice to prove heirship without a full Erbschein.
The Erbschein application:
See our guide on obtaining an apostille for a foreign death certificate for authentication of UK documents for German proceedings.
Germany levies Erbschaftsteuer on inheritances. Germany has a relatively generous allowance system for close relatives:
Tax rates (Class I — spouses, children, grandchildren) range from 7% (on the excess above the allowance up to €75,000) to 30% (on values above €26 million). Class II (siblings, nieces/nephews): 15–43%. Class III (all others): 30–50%.
The UK–Germany double taxation convention on inheritances prevents double taxation between UK IHT and German Erbschaftsteuer. German tax paid on German assets can be credited against the UK IHT liability. Specialist advice on treaty claims is essential.
The German Erbschaftsteuer return must be submitted to the German Finanzamt within 3 months of the tax assessment notice (which the Finanzamt sends after being notified of the death).
For the UK administration, see our estate administration checklist, our complete UK probate guide, and our guide on multiple wills in different jurisdictions.
See our UK IHT guide for current UK thresholds. For the documents needed on the UK side, see what documents you need for probate. For apostilling documents, see our guide on apostilling a foreign death certificate. For recognising a foreign grant in the UK, see our guide on how a foreign grant is recognised in the UK.
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