WEB | Inheritance and Estate Planning Between Germany and Australia – What You Need to Know

You have built up assets in Australia – perhaps also still in Germany. But who inherits what, under which legal system, and what happens if, in a serious situation, no one is able to act? 

Have you inherited something in Germany and want to know what you need to do? 

German–Australian inheritance law is one of the most complex intersections in international private law: two legal systems, two languages, no shared inheritance tax treaty – and powers of attorney that may lose their validity at the border. 

In this presentation, Markus Christmann (Asquith Legal) explains what Germans in Australia – and investors with assets in both countries – should pay close attention to: 

• Australian assets: probate, superannuation, capital gains tax in the event of inheritance  
• German assets: inheritance tax, allowances, EU Succession Regulation  
• Both countries: coordinated wills, cross-border administration, probate, certificate of inheritance  
• Powers of attorney: pitfalls and problems 

Markus Christmann passed both German state exams in law and is admitted to practise as a lawyer in both Germany and New South Wales (as a solicitor). With this dual qualification, he advises clients on both legal systems – in German and in English