Inheritance across borders? One call and you know where to start.
A house in Austria, an account in Germany, a relative who died in Vienna. If the death occurred on or after 17 August 2015, cross-border succession is governed by Regulation (EU) No 650/2012, and what matters is where the deceased was last habitually resident, rather than where the assets lie. I will tell you which court and which law apply to your case, and I will act for you.
Mgr. Barbora Surmanová is an attorney-at-law admitted in the Czech Republic and registered with the Czech Bar Association (No. 13930), with her office in Znojmo, South Moravia, about 70 km from Vienna. She focuses on cross-border succession under Regulation (EU) No 650/2012: probate proceedings connected with Austria, Germany and other EU countries, the European Certificate of Succession and wills with a choice of law. She advises in Czech, German and English, in person in Znojmo or online, working with a sworn translator of German.
Four typical situations
- A house or flat in Austria. The proceedings (Verlassenschaftsverfahren) are conducted by an Austrian notary acting as court commissioner, who corresponds in German. I help you understand what the notary is asking for, keep an eye on the deadlines and arrange the entry in the Austrian land register (Grundbuch) together with the Austrian notary.
- An account or savings in Germany. The bank wants proof that you are an heir. A European Certificate of Succession issued in the Czech Republic is valid throughout the EU without any further recognition. I prepare the application for it; the certified translation is provided by a sworn translator I work with.
- The deceased lived abroad and left assets in the Czech Republic. The proceedings then usually take place in the country of their last habitual residence, and the Czech property is included in them. I explain what follows from that and coordinate the next steps with the notary or court abroad; if the deceased lived outside the EU, I assess whether a Czech court may decide on the assets in the Czech Republic under the conditions of the Regulation.
- You live abroad and are inheriting in the Czech Republic. You need representation in the Czech probate proceedings without having to travel here. I take over the communication with the notary and we handle everything remotely.
What I will do for you
- I assess which country has jurisdiction and which law governs the estate (Articles 4 and 21 of the Regulation).
- I represent you in the Czech probate proceedings and deal with the notary or the court in Austria or elsewhere in the EU.
- I prepare the application for a European Certificate of Succession, or check a certificate issued abroad.
- I file for recognition and enforcement of a foreign succession decision in the Czech Republic; to enforce a Czech decision abroad, I work together with a lawyer or notary in that country.
- I draw up a will with a choice of law (Article 22), so that you determine in advance which law your estate will be governed by.
- We arrange certified translations of German documents alongside the legal work itself; they are produced by a sworn translator I work with on a long-term basis.
I am an attorney-at-law admitted in the Czech Republic (Czech Bar Association No. 13930). I am not admitted in Austria, Germany or the United Kingdom. I advise on Czech law and on the EU rules; for the foreign part of the proceedings I act in cooperation with local notaries, authorities and colleagues.
See all my services →The European Certificate of Succession in brief
The European Certificate of Succession (Europäisches Nachlasszeugnis) is a uniform document proving who the heir, legatee or administrator of the estate is. In the Czech Republic it is issued by the notary who conducts the probate proceedings as court commissioner.
- It is recognised in the EU countries where the Regulation applies, that is, everywhere except Denmark and Ireland, with no apostille and no further procedure.
- A certified copy is valid for six months; after that you can ask for an extension or for a new one.
- It is not compulsory. Sometimes a Czech succession ruling with a certified translation is enough; I will assess which route to take on the basis of what the bank, the land register or the authority actually requires.
In Switzerland, the United Kingdom or the United States the certificate has no effect; assets there are usually dealt with under local rules, and I will tell you when a colleague in that country is needed.
How our work together begins
- The call. In a few sentences you tell me who died, where they lived and what they left behind. The call is there to get a first idea of your situation and to arrange a consultation; the consultation is charged for and I will tell you the rate in advance.
- The consultation. In Znojmo, or by video call. We go through the documents and I explain which country and which law apply in your case, which deadlines are running and what costs to expect.
- Taking on the case. From then on I act for you: with the notary, the court, the bank and the land register, and for steps under foreign law in cooperation with local colleagues. I keep you informed about where the matter stands.
An office close to the Austrian border
Znojmo lies about 70 km from Vienna and only a few kilometres from Retz. I deal with Austrian notaries, authorities and banks directly in German. If you live abroad, we can handle everything remotely: video call, e‑mail, Czech data box.
Contact details and office address →What clients usually ask
A relative died in Austria. Do I have to deal with the estate there, or in the Czech Republic?
What matters is where the deceased was last habitually resident, rather than their nationality or where the assets lie. If they lived in Austria, the proceedings are normally conducted by an Austrian court through a notary and Austrian law applies. There are exceptions, for example a choice of law in a will, so it is worth having the situation assessed first.
What is the European Certificate of Succession and when do I need it?
It is a document under Regulation (EU) No 650/2012 with which you prove your position as heir, legatee or administrator of the estate in another EU country, without any further recognition procedure. In the Czech Republic it is issued by the notary who conducts the estate as court commissioner. It is typically needed for a bank, a cadastre or a land register abroad.
I live in Austria, but I would like Czech law to govern my estate. Is that possible?
Yes. In your will you may choose the law of the country of your nationality. The choice must be express or must follow clearly from the wording of the will. I draw up a will with an express choice of law and advise you on how to store it safely.
Is tax payable on an inheritance abroad?
Tax rules differ from country to country. In the Czech Republic acquiring an inheritance is exempt from income tax; abroad other obligations may arise, for example in connection with real property. I recommend discussing the specific tax consequences with a tax adviser for the country concerned, and I am happy to suggest whom to approach.
Will I need certified translations?
Usually yes: the death certificate, the will, extracts from the cadastre or the land register, court decisions. Translations from and into German are produced by a sworn translator with whom I work on a long-term basis, so we arrange them alongside the legal work.
What should I prepare for the first consultation?
The death certificate, proof of the last residence of the deceased, any will and an overview of the assets country by country. Copies are enough and nothing has to be translated. I tell you the rate for the consultation and the price of any further work in advance.
Not sure where to start? Start with a call.
Call +420 776 253 056 or write to ak@surman.cz. A few sentences about who died, where they lived and what they left behind are enough. If you cannot get through, I normally call back by the next working day and we arrange a consultation.
Call +420 776 253 056 +420 776 253 056