How do family members living in Germany affect the succession plan?

The inheritance and tax laws of both countries come into play together; a flawed setup creates the risk of double taxation and invalid dispositions. With our Berlin–İstanbul team we design the plan so that it holds under both legal systems. The critical question is which country’s succession law applies: under the EU Succession Regulation the estate of a family member habitually resident in Germany will often be governed by German law, and both Turkish and German law protect a reserved share (Pflichtteil). So the transfer and the will are built so as not to breach the reserved share in either country, and to keep double taxation out of the result.