🏛️ Inheritance Tax Germany vs Netherlands Estate Planning 2026

Germany is dramatically better for multi-child families. The German child allowance of €400.000 per child means a couple with three children can transfer €1.200.000 tax-free. Netherlands allows only approximately €22.918 per child. approximately 17x less. Germany's renewable 10-year gift cycle adds further efficiency: €400.000 per child every 10 years enables millions to be transferred tax-free over a 20-30 year planning horizon.

Yes. Germany's Schenkungsteuer applies the same tax-free allowances as inheritance (€400.000/child, €500.000/spouse) and these renew every 10 years. Systematic gifting is the primary estate planning tool in Germany. distributing assets over multiple 10-year cycles can eliminate inheritance tax entirely for large estates. A notary or Steuerberater can assist with structuring gifts to maximise the tax-free cycles available.

A Germany-Netherlands inheritance tax treaty exists but provides limited relief. It generally applies a credit mechanism to prevent pure double taxation on specific asset types. However, the treaty does not eliminate all double-tax risk for complex cross-border estates. particularly where both countries claim taxing rights (Germany because the heir is German resident; Netherlands because the deceased was Dutch resident). Families with significant cross-border connections should seek specialist estate planning advice well before inheritance situations arise.