Many Israeli families own assets outside Israel, or have heirs living abroad. This raises questions a purely local estate does not: which law applies, where to file, and which foreign documents are needed.
Which law applies?
As a rule, the Israeli Succession Law applies the law of the deceased’s domicile at death. For some assets – especially real estate abroad – the country where the asset is located may apply its own rules, so each asset is reviewed separately.
Succession order or probate order in Israel
- Succession order – where there is no will.
- Probate order – where there is a will.
Applications are filed with the Inheritance Registrar, including online. Heirs abroad can sign remotely, subject to authentication rules.
What documents are needed from abroad?
- Death certificate, with an apostille where required.
- Any will made abroad.
- Legal translation into Hebrew of foreign-language documents.
- Heirs’ details and addresses.
See also legal translation.
Wills covering several countries
Make sure the will is valid where needed and does not conflict with another will; a new will may revoke an earlier one.
Tax
Israel currently has no inheritance tax, but other countries may tax assets located there. Selling an inherited apartment in Israel is subject to betterment tax rules – see purchase and betterment tax.
How long does it take?
It depends on obtaining and translating foreign documents and on any objections. The expected stages are explained at the outset.
Wills and inheritance · Lasting power of attorney
General information only; it does not constitute legal advice.