Israeli Law Q&A for France Residents

You need a separate Israeli order. A French acte de notoriété identifies the heirs under French law, but Israel does not treat it as operative title over Israeli assets. An estate with property or accounts in Israel needs its own succession order (tzav yerusha) or will execution order from the Inheritance Registrar under the Succession Law 1965. The acte de notoriété is filed as supporting evidence, apostilled and translated into Hebrew, and an Israeli bank or the Land Registry acts on the Israeli order, not the French deed.

Not directly. French succession often splits ownership into usufruit (use and income) and nue-propriete (bare ownership), typically giving a surviving spouse the usufruct. Israeli land law has no matching concept, and Israeli immovable property is governed by Israeli law, so a French usufruct cannot simply be registered at the Israeli Land Registry. The right usually has to be recreated through an Israeli instrument or a life-use arrangement. Israel levies no inheritance tax on the transfer.

If you are tax-resident in France, yes. The French real-estate wealth tax, IFI, reaches worldwide property, so an Israeli apartment enters the base once your household's net property wealth crosses the threshold. The France-Israel treaty covers income tax only and gives no relief, but Israel has no wealth tax, so there is no double charge, only the French one. Mortgages on the property are deductible, and a French national who is not a French tax resident does not include the Israeli property at all.

Legally an SCI, or any foreign company, can hold Israeli real estate, but it is usually the wrong vehicle. For Israeli tax the SCI becomes a real estate association (igud mekarkein) under the Real Estate Taxation Law 1963, so transfers of its shares are taxed like transfers of the property itself, and it loses the exemptions and reduced purchase-tax rates available to an individual buyer. What is tax-transparent and convenient in France can be opaque and expensive in Israel, so the two-country picture has to be modelled before you buy.

Israel has no forced heirship. Under the Succession Law 1965 you have full freedom of testation and can leave an Israeli apartment or bank account to anyone, with no reserved portion for children. The one real limit is a dependant's maintenance claim (mezonot min ha'izavon) under Sections 56 to 57, which a spouse, minor child, or supported parent can bring at the Family Court. For a French resident this matters because Israeli real estate follows Israeli law, so the French réserve héréditaire generally cannot override a valid Israeli will over an Israeli flat.

Usually yes. As a French tax resident you owe France's social charges (prélèvements sociaux, CSG and CRDS) at 17.2% on Israeli rental income, dividends, interest, and capital gains, on top of French income tax. The France-Israel tax treaty is an income-tax treaty and does not cover these social charges, and the Israel Tax Authority does not reliably allow them as a credit, so they can be a genuine extra cost.

A French *traducteur assermenté* produces an official translation in France, but Israeli authorities usually will not accept it on its own. Israeli law keys acceptance to a Hebrew translation confirmed by an Israeli notary under Section 15 of the Notaries Law 1976, not to the foreign translator's sworn status. The standard chain is: get the French original apostilled by the Cour d'appel, then have an Israeli notary produce or confirm the Hebrew translation. Skipping the Israeli notarial layer is the usual reason documents get rejected at the Inheritance Registrar or *Tabu*.

Not as a marriage. Israel has no civil-partnership institution, and a French PACS is not automatically treated as a marriage under Israeli law. For inheritance, a surviving PACS partner is not an automatic spouse under the Succession Law 1965, but can inherit as a reputed spouse (yeduah b'tzibur) under Section 55 if a shared household is proved. For immigration, a PACS does not confer the automatic rights of a married spouse, and the Population Authority assesses the relationship case by case.

Owning the company is fine; managing it day-to-day from France is the risk. A company incorporated in Israel is Israeli-resident under Section 1 of the Income Tax Ordinance 1961 and pays 23% Israeli corporate tax, but France can claim a company whose effective management sits in France. Where both states claim it, Article 4 of the France-Israel treaty awards residence to the place of effective management, so genuine Israeli management substance is what keeps the company Israeli.

No. A French notaire cannot register a property transfer in Israel. Under Section 7 of the Land Law 1969 an Israeli real estate transaction is completed only by registration at the Land Registry (Tabu), which an Israeli lawyer handles. A French notaire can, however, authenticate a power of attorney that lets your Israeli lawyer sign for you, once it is apostilled.

Yes. A French resident can own up to 100% of an Israeli company under the Companies Law 1999 without living in or even visiting Israel. The company pays Israeli corporate tax at 23%, dividends paid to a French shareholder face Israeli withholding capped by the France-Israel tax treaty, and France requires you to report the foreign shareholding and the dividends on your French return. A French tax credit prevents the same income being taxed twice.

Yes. Making aliyah and receiving Israeli citizenship under the Law of Return 1950 does not require you to renounce French nationality, and France does not strip your citizenship when you acquire another one. You become a dual French-Israeli national. France permits dual nationality, and Israel permits it for olim under the Citizenship Law 1952, so both passports remain valid.