Living abroad often creates unique inheritance and succession issues. International families frequently have assets, family members, and legal connections in more than one country. Without proper planning, this can lead to uncertainty, unintended outcomes, and unnecessary complexity for future heirs.

I advise expatriates, foreign nationals, international couples, and globally mobile families on German inheritance law and cross-border estate planning matters.

The objective is to create legally sound estate arrangements that provide clarity, protect beneficiaries, and function effectively across jurisdictions.

Why Estate Planning Matters for International Families

Many international residents assume that inheritance matters will be governed by the law of their nationality or by the law of the country where their assets are located.

In practice, international succession can be considerably more complex and careful planning can help reduce uncertainty and avoid disputes among future heirs.

Questions frequently arise regarding:

• The law applicable to the succession
• Wills made in different countries
• Assets located in multiple jurisdictions
• Family members residing abroad
• Real estate located in Germany
• Recognition of foreign wills
• Tax considerations in different countries

Estate Planning for Expats Living in Germany

Foreign nationals living in Germany often become subject to legal rules that differ significantly from those in their home country.

Particular attention may be required where:

• Different nationalities are involved
• One spouse is German and the other is not
• Children hold multiple citizenships
• Property is located in Germany and abroad
• Previous wills exist in another country
• Family members reside in different jurisdictions

Choice of Law in International Estates

In many international estates, one of the most important questions is which country's inheritance law will ultimately govern the succession. Under certain circumstances, a choice of law may be made in a will. Depending on the situation, this can significantly affect the distribution of assets and the rights of family members. Determining the applicable law is often one of the central issues in international estate planning.

Wills for International Couples and Families

A will that works well in one country may not always achieve the intended result in another. The objective is not merely to create a valid will, but to ensure that the estate plan functions effectively when it is eventually needed.

International families frequently require wills that take into account:

• Multiple nationalities
• Assets in different countries
• Different legal systems
• Existing foreign estate planning documents
• Cross-border family structures

Property in Germany and Assets Abroad

Many expatriates own property in Germany while maintaining assets in their country of origin or elsewhere.

This often raises questions concerning:

• Ownership structures
• Succession planning
• Coordination of estate documents
• Cross-border administration of the estate
• Future transfer of assets to heirs

Common Issues in International Estate Planning

International estate planning frequently involves:

• Multiple citizenships
• Cross-border marriages and partnerships
• Children residing in different countries
• Existing foreign wills
• German and foreign real estate
• Family businesses
• International investment portfolios

Legal Framework

The legal framework will depend on factors such as nationality, habitual residence, family structure, asset location, and any choice of law contained in a will.

Estate planning for Germany may involve:

• Regulation (EU) No. 650/2012 (EU Succession Regulation)
• German Civil Code (BGB)
• Applicable foreign inheritance laws
• Bilateral and international private law rules between Germany and countries such as Turkey and the Russian Federation.