In all events of successions to German people with assets in Greece assets or to Greek people with assets in Germany the German-Greek international inheritance law is affected.

Of you've got questions or problems we shall help you quickly, professionally, and reliably.
Please contact
Mr Volker Schernikau, Solicitor (email: schernikau@psbr.de, phone: 05193/98610) or
Mr Paschalis K. Lampropoulos, Solicitor at our associate law office in Theassaloniki (phone: 00302 31 0535588 u. 547487).


The following scheme shows you some differences and some similarities between Greek and German inheritance law.

Gebiet	Deutsches Recht	Griechisches Recht
Statute of inheritance (International Private Law/Law of Conflict of Laws)	art. 25 para. 1 EGBGB: nationality at the time of death	art. 28 ZGB: nationality at the time of death
Acquisition of nationality	StAG: ius sanguinis, may lead to double nationality	Kodikas Ellinikis Ithangenias (Kodex der griech. Staatsangeh.): ius sanguinis, may lead to double nationality; if thus no nationality is acquired: ius soli
Cross-reference (Int. Pr. Law)	must be followed according to art. 4 para. 1 EGBGB; may lead to splitted inheritance	art. 28 ZGB: cross-reference by foreign international private law is not allowed, leading to an undivided inheritance as a matter of principle
Choice of Law	Partially allowed: art. 15 para. 2 EGBGB (marriage law); art. 25 para. 2 EGBGB (inheritance law)	No choice of law allowed
Testamentary Capacity	age 16, para. 2229 sect. 1 BGB	age 18, art. 1719 ZGB
Contract of Inheritance	allowed, para. 2274 ff. BGB; gift causa mortis is also allowed and treated like a disposition mortis causa (para. 2301 BGB)	not allowed, art. 368 ZGB. possible alternatives: legacy contract, gift causa mortis, art. 2032 ff. ZGB (regulations about gifts are applicable)
Common Will	allowed for married couples, para. 2265 BGB	not allowed, art. 1717 ZGB.
Statutory Portion	beneficiaries: descendants, parents, spouse, art. 2303 BGB. extent: half of the legal inheritance. The statutory portion consists in a liability of the estate, thus the beneficiary will not be a heir.	beneficiaries: descendants, parents, spouse, art. 1825 ZGB. extent: half of the legal inheritance. beneficiary becomes a joint heir.