Deceased Estates, Inheritance and Assets Abroad
Deceased Estates Abroad Require Specialised Legal Knowledge
If the deceased had assets abroad, a thorough understanding of how deceased estates are administered in the country concerned is required. Advokathuset Bredgade can assist with legal and practical matters. The administration of a deceased estate abroad often involves both Danish and foreign rules, which must be properly coordinated. Advokathuset Bredgade also has contacts with notaries and probate courts in many European cities and outside Europe, enabling us to assist with the transfer of assets abroad and dealings with the authorities.
The rules governing international deceased estates in the EU are laid down in the EU Succession Regulation (Regulation (EU) No 650/2012), which you can read in full on EUR-Lex.
If the Deceased Lived Abroad
If the deceased lived abroad, the deceased estate must be administered in accordance with the rules applicable in the country where the deceased lived. This often requires contact with a notary or probate court in that country. Advokathuset Bredgade has contacts with notaries and probate courts in many European cities and outside Europe, enabling us to assist with initiating the estate administration and transferring assets and properties.
Deceased Estates and Inheritance Abroad Require Specialised Knowledge
A deceased estate abroad can be complex, particularly if it includes real estate, bank accounts or companies in several countries.
Advokathuset Bredgade has extensive experience with deceased estates abroad and a large network of lawyers, notaries and probate courts abroad specialising in estate administration. Please contact us for an overview and assistance with administering the deceased’s estate and assets abroad.
For advice on deceased estates or assets in the USA and England, please contact lawyer Claus Christian Hansen.
For advice on deceased estates in Italy, Spain, Portugal, Germany or France, please contact lawyer Sandra Moll Dirscherl.
Frequently Asked Questions
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If the deceased left assets abroad, the estate must normally be administered in accordance with the rules of the country where the assets are located, and both the probate and tax rules of that country should be clarified. Local authorities and possibly local legal assistance are often necessary.
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As a general rule, the deceased estate is administered in the country where the deceased had their habitual residence at the time of death. If the deceased had assets in several countries, the estate may be administered in parallel under the respective countries’ rules, particularly in relation to real estate.
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Yes. Inheritance may be taxable both in the country where the deceased lived and in the country where the asset is located. In Denmark, for example, estate duty is only payable on assets connected to Denmark if the deceased lived abroad.
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You will typically need to obtain a death certificate, certificate of estate administration, will, proof of ownership of assets and documentation of the deceased’s residence. Requirements vary from country to country, so local legal advice is essential.
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Legal advice should be sought early in the process – particularly if there are assets in several countries, disagreements about the applicable rules or if the tax and probate procedures are complex, in order to avoid mistakes and additional costs.
