top of page

Cross-border inheritance

The term "cross-border inheritance" usually refers to a situation in which a person dies and his property or other rights are transferred across the border of one or more countries. This can lead to complex legal and tax issues as each country may have its own laws and regulations regarding inheritance.


Cross-border inheritance can include various elements, such as real estate in different countries, cash in bank accounts abroad, the value of shares or other financial assets in international companies, intellectual property, and the like.


Due to different legal systems, tax laws and other factors, problems can arise when regulating a cross-border inheritance. Some countries have bilateral or multilateral agreements that govern cross-border inheritances and determine which laws apply and how property is taxed.


The registration of ownership rights to real estate in the event of inheritance abroad may require certain procedures and formalities depending on the legal system and legislation of the country in which the property is located. Below are some general steps you should take when inheriting property abroad:


Check local laws: Check the legal regulations in the country where the property is located. Each country has its own laws and procedures regarding inheritance and registration of property rights.


Obtain a certificate of inheritance: Obtain an official certificate of inheritance or other document required by the legal system of the country where the inheritance occurred. This certificate will probably contain information about the heirs and their shares.


Translate documents: If the documents are in a foreign language, you may need to translate them into the official language of the country where the property is located.


Obtain the necessary forms: Check if you need to fill out any title registration forms and collect them from the local authorities or notary's office.


In Europe, the registration of property rights has been simplified by the European Certificate of Succession, which is a standardized certificate that allows a simpler inheritance process in cross-border cases within the European Union. This certificate enables the recognition and enforcement of the inheritance decision made in an EU member state in other member states.


To obtain a European certificate of inheritance, you can follow these steps:


Determine the competent authority: To obtain a European Certificate of Succession, you must contact the competent authority in the country where the deceased person had their last habitual residence. In most cases this is a notary or a court. You can find information on these pages:


Obtaining an inheritance decision: You must first obtain an inheritance decision from the competent authority of the country where the inheritance took place. This decision must be consistent with the rules and procedures of that country.


Request a European Certificate of Succession: Next, contact the relevant authority in that country (e.g. a notary or a court) and request a European Certificate of Succession. Typically, you will need to submit the required documents, such as: B. the certificate of inheritance, identification documents of the heirs, etc.


Download the certificate: Once the European Certificate of Succession has been issued, you will receive it in physical or digital form. With this certificate you can also exercise your heir rights in other EU member states.


The key here is to remember that procedures may be slightly different in each EU member state. Therefore, it is always advisable to consult a lawyer with experience in cross-border inheritances to ensure the correctness of the procedures and the proper fulfillment of the requirements.

3 views0 comments

Recent Posts

See All


bottom of page