Succession: Germany → Germany

Which law decides who gets what

The testator lives in an EU country (Germany). Under the common European rules the whole estate is governed by that country's law — wherever the assets are.

Who the law forces you to include

Germany: Pflichtteil — a monetary claim ≈ half of the intestate share (not an in-rem share).

A workable route: choose the applicable law in the will in advance and/or move assets into a structure (foundation, trust, holding) where shares are inherited rather than the assets themselves.

Where tax arises

Germany: Erbschaftsteuer — progressive; allowances: spouse €500k, children €400k; higher rates for distant relatives.

How it is recognised and processed

Within the EU there is a single document — the European Certificate of Succession: it is recognised across all EU states, with no need to go through the procedure in each one.

What to set up in advance

Will with a choice of applicable law

Trust

Private foundation

Insurance wrapper for assets

Part of the estate is reserved by Germany law for close relatives — it cannot be freely reallocated by will.