Inheritance DE ↔ ES
The double-taxation treaty between Germany and Spain does not cover inheritance tax. We make sure your estate is not taxed twice.
What we do
Complete cross-border estate planning.
Wills & agreements
Drafted to be valid in both legal systems, including notarial deed in Spain.
Tax planning
Structure your assets so inheritance tax applies once — and only as far as unavoidable.
Lifetime transfers
Give instead of bequeath — with a clear view of allowances in Germany and Spain.
Succession handling
From death certificate to land-registry entry — the entire process.
Tax declarations
Inheritance-tax filings in Spain (Modelo 650) and Germany, coordinated with both offices.
Disputes
Representation before Spanish courts if the community of heirs cannot agree.
Germany vs. Spain
Where the two systems diverge.
Quick overview of key differences — every case requires individual analysis.
| Aspect | Germany | Spain |
|---|---|---|
| Applicable inheritance law | BGB — compulsory portion, statutory succession | Código Civil — different quotas, Balearic Foral law |
| Inheritance tax | Allowances by relationship, up to 50 % | Balearic Islands — substantially reduced for close relatives |
| Double-taxation treaty | Covers income tax | Does not cover inheritance |
| Required documents | Erbschein, will | Certificado de últimas voluntades, escritura de aceptación |
| Filing deadline | 3 months from knowledge | 6 months from date of death (extendable) |
Note: overview only; does not substitute individual advice.
Process
Three structured steps.
Inventory
Assets in DE and ES, family structure, existing wills, tax IDs, real estate.
Strategy
Wills and gifts structured with a clear tax projection in both countries.
Execution
Notaries, registries, ongoing support — including adaptation to legislative changes.
Your succession deserves structure — not chance.
We assess your situation and propose a concrete next step.