German-Russian cases of inheritance and the relation with the EU Regulation on Succession cases
The new Regulation of the EU on cases of succession has been in force since 17.08.2015 – which might have effect also on cases with Third States – concerning German-Russian inheritance only in part.
In the relation between Germany and Russia the „old“ Consulate Treaty between the two States – more precise: Germany and the Soviet-Union – has to be applied. This is also true for the relation between Germany and Armenia, Germany and Azerbaijan, Germany and Belorussia, Germany and Georgia, Germany and Kazakhstan, Germany and Kirghizia, Germany and Moldavia Germany and Tadzhikistan, Germany and the Ukraine and Uzbekistan – all these countries are still comprised by the scope of the named treaty.
According to the treaty, concerning immovable property is governed by the law where it is situated.
In other aspects the new EU-Regulation needs to be applied. This means mainly the competence of courts and other state-authorities as well as the law concerning movable property belonging to the estate.
In case you have any query in this respect you can contact me here. In my office we can also work in the Russian language.
