Title says is all really...
If I transfer a significant sum as a gift without reservation to a daughter living in Germany, DAK if she can be taxed on the transfer in some way by the German IRS.
On my side of the coin, I haven't seen anything in HMRC's publications to indicate that gifts to donees abroad are outside of PETs (but perhaps I have missed something), so I realise that if I die before the 7-year PET window is up, I assume she is liable to be taxed by HMRC. How this would work I don't know; perhaps in this instance HMRC don't bother and just go direct to the estate for the money.
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Any donee tax on money gifts to someone in Germany?
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- Lemon Half
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Re: Any donee tax on money gifts to someone in Germany?
stewamax wrote:perhaps in this instance HMRC don't bother and just go direct to the estate for the money.
Surely in most instances they "go direct to the estate for the money".
Scott.
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- The full Lemon
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Re: Any donee tax on money gifts to someone in Germany?
My understanding is that Germany taxes the beneficiary rather than the estate. In other words it is a true inheritance tax whereas what the UK has should in fact be called an estate tax.
This could have important implications for a German beneficiary of a gift or bequest from a UK donor, since it could end up being taxed twice, i.e. by both jurisdictions. Whereas a UK beneficiary of a German gift or bequest might escape tax altogether.
These folks seem to know a lot:
http://www.crosschannellawyers.co.uk/ge ... ne-glance/
This could have important implications for a German beneficiary of a gift or bequest from a UK donor, since it could end up being taxed twice, i.e. by both jurisdictions. Whereas a UK beneficiary of a German gift or bequest might escape tax altogether.
These folks seem to know a lot:
http://www.crosschannellawyers.co.uk/ge ... ne-glance/
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- Lemon Quarter
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Re: Any donee tax on money gifts to someone in Germany?
Tnx Lootman. The link you provided is most useful - and a bit scary with the possibility of double taxation when HMRC taxes the estate and the German IRS then taxes the legatee.
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