In Poland, the estate is subject to tax if and to the extent that it is located on the territory of Poland or is exercised there as a property right. An estate located abroad is only taxable in Poland if the acquirer or the deceased was a Polish citizen or had their permanent residence in Poland. If neither the heir nor the deceased was a Polish citizen or resident in Poland, the acquisition is tax-free. For the above, see Art. 1-3 polErbStG.
If the heir is a German national who has not lived abroad for more than five years or other persons who have their domicile or habitual residence in Germany, they are subject to unlimited tax liability in Germany with regard to the acquisition of the inheritance (Section 2 ErbStG). This can therefore lead to Double taxation of heirs come. The only possible remedy would be a Crediting of taxes already paid abroad. However, this can only on real estate and business assets be made, § 21 ErbStG. If you have any further questions, please contact your specialist inheritance lawyer in Düsseldorf and Krefeld, Dr Michael Gottschalk.