Comparative Analysis of Current Problems of Hereditary Law of Russia and Germany

This article delves into both theoretical and practical aspects of hereditary law development in two different countries: Russia and Germany. The authors investigate the varied approaches taken in each country towards the legal responsibility of heirs for the testator’s obligations and the sale of inheritance. They attempt to identify the key characteristics of heirs’ responsibility for their testator’s obligations as well as the specific details of inheritance sales within the context of German law.

The article examines the norms of hereditary law in Russia and Germany by conducting a comparative analysis of civil law, doctrine, and practice. It proposes several potential solutions to issues discussed and focuses on studying the norms that determine heirs’ responsibility for the testator’s obligations and the peculiarities of inheritance sales in German law.

This article focuses on the study of civil law norms that relate to the responsibility of heirs for their testator’s obligations, and the distinct characteristics of inheritance sales in German law. It also examines the legal doctrine, judicial practices, and notarial practices in Russia and Germany.

The objective of the article is to develop a comprehensive understanding of the inheritance sales institution in German law and identify methods to address critical challenges in determining heirs’ responsibility for the testator’s obligations in civil law in Russia and Germany.

As part of the investigation, general scientific and private scientific methods were used, such as analysis, comparison, structural, systemic and functional approaches, etc. The basis of the scientific study was the methods of comparative analysis, analytical and functional approaches, through which the most pressing nuances of modern hereditary law of Russia and Germany were identified.