What's the issue with dual nationality?

326 posts in this topic

On 12/16/2021, 9:03:17, alexunterwegs said:

At the same time, you need to be aware that having a second nationality has implications for things like taxation, inheritance or even military service, were it to be re-introduced. 

 

Taxation in Germany is based on residency and not citizenship. Only the US has citizenship based taxation.

Residency of the person inheriting, has relevance under the German system, as well as a whole bunch of other stuff.

Military service is actually citizenship based, but I would guess(?) you can't be called up if you are not living in the country.

I am guessing again, those who obtain citizenship later in life are not retrospectively asked to do military service, but I guess some countries might require this also, depending on someone's age/sex and how relevant this was today.

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5 hours ago, jonathanp said:

You lose German citizenship if you take the active decision to apply for another citizenship. 

Dual citzen can lose German if they join a foreign army (lots of exceptions) and also if you join a banned terrorist organisation.   But again, hardly out of the blue.  The second is a recent change in law, and not restrospective.    Unlike in the UK.

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26 minutes ago, scook17 said:

Only the US has citizenship based taxation

And Eritrea  😂

Quote

Residency of the person inheriting, has relevance under the German system, as well as a whole bunch of other stuff.

Residency in 🇩🇪 governs inheritance tax, but citizenship/s of German residents can affect what testament is enforceable.  That can be very important in some cases, such as mine, which may be an outlier here.  But it’s good for all to know.  Inform one’s self.

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13 minutes ago, BethAnnBitt said:

And Eritrea  😂

Residency in 🇩🇪 governs inheritance tax, but citizenship/s of German residents can affect what testament is enforceable.  That can be very important in some cases, such as mine, which may be an outlier here.  But it’s good for all to know.  Inform one’s self.

 

Sorry if this question has been discussed earlier but I have not been following this thread and there are a lot of posts. If as a resident but non German citizen I receive an inheritance from the UK that either has had death duties deducted or is under the threshold for death duties, would I be subject  to German inheritance taxes on it or only if I had dual German/UK citizenship

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10 minutes ago, keith2011 said:

If as a resident but non German citizen I receive an inheritance from the UK that either has had death duties deducted or is under the threshold for death duties, would I be subject  to German inheritance taxes on it

Yes, you would be subject to it.

Please read: 

The UK inheritance tax you had already paid on that inheritance would reduce your German inheritance tax, i.e. you would get a tax credit for it.

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