Das Verhältnis von Erbschein und Europäischem Nachlasszeugnis

This monograph focuses on the relationship between national certificates of inheritance and the European Certificate of Succession created by Regulation (EU) No 650/2012 – a topic hardly regulated by law. Both documents are equivalent proof of inheritance in matters of international succession but differ in their issuing procedures and legal effects. This monograph is dedicated to the complex questions which arise at the point where the inheritance statute, the matrimonial property statute and the statute on property law intersect. It primarily focuses on the question of which factors can lead to a divergence between the German certificate of inheritance and the European Certificate of Succession, how such a divergence can be avoided and what legal consequences are linked to such a contradiction.