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Advice on International Inheritance Tax 

Personal relationships and asset structures are becoming increasingly international. Different nationalities within a family, foreign assets owned by domestic residents, and domestic assets in the possession of foreign nationals are all situations which are now the norm, not the exception. And we are not just talking about holiday homes; this area also covers substantial foreign property portfolios or stakes in foreign firms.  

Asset transfers with a foreign component touch upon foreign civil and tax law systems and are therefore far more complicated than purely domestic transfers. The following issues come into the frame:  

  • Taxation of the same process by several countries  
  • Avoidance of multiple taxation  
  • Evaluation of assets  
  • Tax-optimisation arrangements 

Since the systems of inheritance and gift tax of individual states are not harmonised, there can be many overlaps in this area.  

We provide advice on how to structure your foreign assets and suggest how to avoid, if possible, the same assets being taxed twice. Both in the case of inheritance and inter vivos gifts, we are able to make all the necessary in-country tax declarations on your behalf. By working closely with our Crowe Horwath International partners, we are also able to ensure that your foreign tax obligations are promptly fulfilled.  


Contact Us
Wolfgang Kirschning
Reutlingen, Germany
+49 7121 489-265

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