Last updated: 7 Nov 2025
Germany–US Inheritance: Examples & Calculations
Step-by-step computations for typical Germany–US estates. We show allowances, tax classes and rates, §21 ErbStG foreign-tax credits, and where family-home or business reliefs apply. Use together with our German Inheritance Tax Calculator.
- Example 1 — German-domiciled decedent; child inherits US portfolio + DE home
- Example 2 — US-domiciled decedent; spouse in Germany inherits US house + DE brokerage
- Example 3 — Business shares with §13a/13b relief and §21 credit
- Example 4 — Family-home exemption for child (200 m² cap)
- Computation tips & quick formulas
- Next steps & templates
Example 1 — German-domiciled decedent; child inherits US portfolio + DE home
Facts: Decedent domiciled in Germany. Sole heir is an adult child (Class I). Assets at death:
- US securities portfolio: €1,200,000 (US-situs)
- German owner-occupied home (not used by heir post-death): €600,000
- Estate debts / costs (lump sum chosen): €10,300
- No prior gifts in last 10 years.
| Step | Calculation | Result |
|---|---|---|
| Gross acquisition | €1,200,000 + €600,000 | €1,800,000 |
| Less allowance (child) | €400,000 | €1,400,000 |
| Less deductions | €10,300 (lump sum) | €1,389,700 taxable base |
| Rate (Class I) | €1,389,700 ⇒ bracket ≤ €6,000,000 → 19% | German tax on total: €264, +? Wait |
We now compute precisely:
| German tax on total | €1,389,700 × 19% | €264, +? |
|---|---|---|
| = €1,389,700 × 0.19 = €264, +? compute exactly below | ||
Exact multiplication: €1,389,700 × 0.19 = €264, +? (19% of 1.3897m = 0.19 × 1,389,700 = 263,? Wait, 10% is 138,970; 20% is 277,940; 19% is 277,940 − 13,897 = 264,043). → €264,043.
§21 ErbStG credit (US securities slice)
Foreign slice = US portfolio €1,200,000. We attribute German tax proportionally to the foreign slice:
| Item | Calc | Result |
|---|---|---|
| Foreign slice proportion | €1,200,000 / €1,800,000 | 66.67% |
| German tax attributable to foreign slice | €264,043 × 66.67% | €176,029 (credit ceiling) |
| US estate tax actually paid on portfolio | assume €150,000 | €150,000 |
| Credit allowed in Germany | min(€150,000, €176,029) | €150,000 |
| German tax payable after credit | €264,043 − €150,000 | €114,043 |
If the child were to self-occupy the home for 10 years, the family-home exemption could reduce the German base further. See Example 4.
Example 2 — US-domiciled decedent; spouse in Germany inherits US house + DE brokerage
Facts: Decedent domiciled in the US. Surviving spouse lives in Germany (Class I). Assets:
- US family home: €900,000 (US-situs)
- German brokerage account: €300,000
- Debts/deductions: €10,300 lump sum
- No prior gifts.
| Step | Calc | Result |
|---|---|---|
| Gross | €900,000 + €300,000 | €1,200,000 |
| Allowance (spouse) | €500,000 | €700,000 |
| Deductions | €10,300 | €689,700 taxable |
| Rate (Class I) | €689,700 ⇒ bracket ≤ €600,000? No, it exceeds; ≤ €6,000,000 → 19% | German tax on total: €131,043 |
Check: €689,700 × 0.19 = €131,043.
§21 credit on US home slice
| Item | Calc | Result |
|---|---|---|
| Foreign slice proportion | €900,000 / €1,200,000 | 75.00% |
| German tax attributable to US slice | €131,043 × 75% | €98,282 |
| US estate tax paid on the house | assume €110,000 | €110,000 |
| Credit allowed | min(€110,000, €98,282) | €98,282 |
| German tax payable | €131,043 − €98,282 | €32,761 |
Example 3 — Business shares with §13a/13b relief and §21 credit
Facts: Child (Class I) inherits:
- Shares in a qualifying German family company: €2,000,000 (eligible for 85% relief)
- US securities: €500,000
- No debts; no prior gifts.
| Step | Calc | Result |
|---|---|---|
| Gross | €2,000,000 + €500,000 | €2,500,000 |
| Apply business relief (85%) | €2,000,000 × 15% taxable | €300,000 taxable portion |
| Adjusted gross for ErbSt | €300,000 (business taxable part) + €500,000 (US) | €800,000 |
| Allowance (child) | €400,000 | €400,000 taxable |
| Rate (Class I) | €400,000 ⇒ bracket ≤ €600,000 → 15% | German tax on total: €60,000 |
§21 credit for US securities slice
| Item | Calc | Result |
|---|---|---|
| Foreign slice proportion (by gross before allowance) | €500,000 / €2,500,000 | 20.00% |
| German tax attributable to US slice | €60,000 × 20% | €12,000 |
| US estate tax on those securities | assume €18,000 | €18,000 |
| Credit allowed | min(€18,000, €12,000) | €12,000 |
| German tax payable | €60,000 − €12,000 | €48,000 |
If the 100% option relief were available and conditions met, the company portion could be fully exempt—re-run with our calculator.
Example 4 — Family-home exemption for child (200 m² cap)
Facts: Child inherits German family home (living space 220 m², value €800,000) and commits to own use for ≥10 years. No other assets, no debts.
| Step | Calc | Result |
|---|---|---|
| Tax-free portion | 200 m² / 220 m² × €800,000 | €727,273 exempt |
| Taxable residue | €800,000 − €727,273 | €72,727 |
| Allowance (child) | €400,000 | Residual €0 → no German tax |
If self-use stops within the holding period, the exemption may be clawed back. Plan occupancy and fallbacks.
Computation tips & quick formulas
- German taxable base = (Gross assets after specific reliefs) − (personal allowance) − (deductions).
- Rate = single rate from the class I/II/III table for the entire taxable base (not marginal).
- German tax attributable to foreign slice (proxy) = (Total German tax) × (Foreign gross slice ÷ Total gross). Document your method in the §21 memo.
- Credit allowed = min(Foreign death tax paid on the slice, German tax attributable to that slice).
- Keep a bridge memo from US FMV → German values (BewG, reliefs) for each asset.
Next steps & templates
Run your numbers
Use our calculator for allowances and rate bands. Then build a §21 worksheet per country.
Templates & services
Get the editable credit worksheets, reconciliation memo, and bilingual checklists.
Also see: Real estate & business · Executor · Trusts & foundations