International Context

Especially in real estate law and inheritance law, it can play an important role in the proper drafting of contracts or wills if one or more parties have their domicile or habitual residence abroad or hold a nationality other than German.
For example, if a foreign couple wishes to jointly purchase a property located in Germany, the question arises as to whether they—just like German spouses—can acquire the property in shares, or whether only forms of acquisition under the law of their nationality are available, such as the “community of accrued gains.”
For succession by reason of death, the EU Succession Regulation has applied to cases of inheritance since August 17, 2015. According to this regulation, the law of the country in which the decedent had their last habitual residence at the time of death generally applies. However, the EU Succession Regulation offers the option of a so-called choice of law, so that German succession law may also be chosen, provided that the choice of law is notarized. If the estate includes real estate located abroad—e.g., a vacation home in Mallorca—this may result in what is known as “division of the estate,” meaning that individual items of the estate may be inherited according to the rules of different legal systems. Here, too, there is an increased need for careful planning.
Finally, an international connection affecting contract drafting may also arise in family and corporate law. In family law, this is the case, for example, with divorce settlement agreements involving foreigners; in corporate law, it applies to the formation of a German corporation by foreigners or to cross-border mergers of companies under the German Transformation Act.
As I am sufficiently proficient in the English language, I also authenticate documents in English upon request or translate my documents into English if this is required in international legal transactions. This applies in principle to all notarial services.
My permanent deputy notary, who is himself a notary in Frankfurt am Main, is also happy to certify and notarize documents in French or Spanish.