Germany

Hamburg Families and Spanish Inheritances: A Complete Guide

Published April 2025 · 8 min read · By International Inheritance Spain

Hamburg, Germany's second-largest city and a major international hub, has a large population with ties to Spain. The proximity to Barcelona (a short flight) and the popularity of the Canary Islands among Northern Germans means that Hamburg-based heirs frequently deal with Spanish inheritances.

Signing Documents from Hamburg

Hamburg residents can sign a Spanish power of attorney at the Spanish Consulate in Hamburg — at Moorweidenstrasse 16–18, 20148 Hamburg. Alternatively, a Hamburg Notar can witness the signature on the document, which is then apostilled by the competent Hamburg authority.

The Germany-Spain Tax Treaty in Practice

For Hamburg families inheriting in the Canary Islands (Tenerife, Gran Canaria) — very popular with Northern Germans:

• Canarian inheritance tax is near zero for direct relatives (99% regional reduction)
• German Erbschaftsteuer applies with its large allowances (€400,000 per child)
• Treaty credit: near-zero Spanish tax means minimal credit; German tax applies on the Spanish assets above the German allowances
• Effective combined rate for a child inheriting a €400,000 Tenerife apartment: approximately 0% (within German allowance)

For Hamburg families inheriting in Cataluña (Barcelona area), the situation is different — see our Spain vs Germany tax comparison article.

European Certificate of Succession

German heirs can obtain a European Certificate of Succession from the Hamburg Nachlassgericht or a Hamburg Notar. This document is valid throughout the EU, including Spain, without apostille or translation — a significant practical advantage.

What If the Deceased Was Living in Spain?

If the deceased was a German national who was habitually resident in Spain at the time of death, Spanish succession law applies to the entire estate under EU Succession Regulation 650/2012 (unless they had previously exercised professio iuris choosing German law). Spanish forced heir rules (legítima) would then govern the distribution of assets.

Coordination with German Probate

For Hamburg families, we coordinate the Spanish process with the German Nachlassgericht (Probate Court) where necessary, ensuring that the two processes proceed in parallel and that the treaty credit is correctly applied in the German inheritance tax return.