This article explores the question of the ‘recognition’ of the material effects of legacies by vindication (legatum per vindicationem), if such legacies concern the right of ownership of immovable property located in an EU Member State the law of which does not provide for such legacies to have a direct material effect, such as Germany. The authors analyse this question in the light of the first judgement issued by the Court of Justice of the European Union on the European Union Regulation No. 650/2012 on Succession and Wills, the Kubicka case (C-218/16). [---] The article’s final part maps out the implication of the Kubicka judgment for the theory and practice of European succession law.