French Heir Administering an Israeli Estate

A daughter in Lyon learns that her late father, who left France decades ago, held a small apartment in Netanya and a dormant account at an Israeli bank. Her French notaire has opened the succession, drawn up the acte de notoriété, and settled the French side. Then she discovers that none of it moves the Israeli assets an inch. The bank in Israel will not speak to her, and the Land Registry will not change a single name without a document she has never heard of.

This is the recurring shape of a French inheritance with an Israeli component. Two legal systems, two sets of paperwork, and no automatic bridge between them. France runs succession through the notaire; Israel runs it through a government registrar and, where needed, the courts. A French heir who treats the Israeli assets as an afterthought to the French estate usually loses months and pays twice for translations and apostilles. Handled in the right order, the Israeli side is manageable from France without ever boarding a plane. If you also need to give an Israeli lawyer authority to act, our guide to the Israeli notary power of attorney for French residents sets out exactly how that document is prepared and apostilled.

Two Parallel Systems That Do Not Talk to Each Other

The single most important thing to understand is that the French succession process and the Israeli succession process are independent. Settling one does nothing for the other.

In France, the notaire is the central actor. The acte de notoriété identifies the heirs and their shares, the déclaration de succession is filed with the French tax administration, and the notaire distributes the French estate. For assets located in France, this is complete and sufficient.

In Israel, there is no notaire equivalent in this role. To establish who inherits and to unlock Israeli assets, you need either a succession order (tzav yerusha) where there is no will, or a will execution order (tzav kiyum tzava'a) where there is one. Both are issued by the Inheritance Registrar (Rasham HaYerushot) at the Ministry of Justice, or by the Family Court if the matter is contested. The French acte, however carefully prepared, has no standing before the Israeli Land Registry or an Israeli bank.

So a French heir with Israeli assets is, in practice, running two estates at once. The good news is that the Israeli order can be applied for from abroad, and the heir does not need to repeat the French exercise in Israel from scratch.

In Practice: Under Section 39 of the Succession Law 1965, the application for a succession order is filed with the Inheritance Registrar (Rasham HaYerushot) at the Ministry of Justice. The state filing fee is about NIS 550, plus a publication fee of roughly NIS 130 for the mandatory newspaper notice. An uncontested order is generally issued within three to five months. A French heir signs the application and supporting affidavits remotely, before a notaire in France, with apostille.

Which Law Decides Who Inherits

A French family often assumes French inheritance rules follow the assets everywhere. They do not, and the interaction is one of the genuinely difficult parts of these estates.

Section 137 of the Succession Law 1965 sets the Israeli conflict-of-laws rule: succession is governed by the law of the deceased's domicile at the time of death. If the father was domiciled in France, French succession law may govern the movable estate. Immovable property situated in Israel, such as the Netanya apartment, is dealt with under Israeli law as the law of the place where the property sits.

This is where French réserve héréditaire, the forced-heirship rule that reserves a fixed portion of the estate for children, can collide with Israeli law, which gives a testator far broader freedom to dispose of property as they wish. Where there is a will, the question of whether a child's reserved share under French law can be asserted against Israeli assets is genuinely contestable and depends on the precise facts of domicile and the wording of the will. This is not a box-ticking exercise. It is the kind of analysis that should happen before any order is applied for, because the wrong assumption here can be expensive to unwind.

No Israeli Inheritance Tax, But France Still Taxes You

Here is the part that surprises most French heirs, in a good way and then a bad way.

Israel abolished estate and inheritance tax in 1981. There is no Israeli tax simply on inheriting the apartment or the bank balance. The Israeli cost appears later, when an inherited property is sold, in the form of betterment tax, but the act of inheriting is not taxed.

France is a different story. As a French resident heir, you are liable for droits de succession on your worldwide inheritance, including the Israeli assets, under Article 750 ter of the Code général des impôts. In the direct line, between parent and child, French law allows an abatement of EUR 100,000 per parent per child, after which the rates climb on a progressive scale to 45%. Because Israel levies no inheritance tax, there is no foreign inheritance tax to credit against the French bill, so the French liability on the Israeli assets is effectively borne in full.

A worked sense of scale: an inherited Netanya apartment valued at EUR 400,000 (roughly NIS 1,600,000), passing to one child, can generate French droits de succession in the region of EUR 60,000 to EUR 78,000 once the abatement and the progressive rates are applied. That tax is owed in France even though the asset sits in Israel and produced no Israeli inheritance tax at all. The French déclaration de succession is generally due within six months of a death occurring in France, or twelve months where the death occurred abroad, and interest accrues on late payment.

In Practice: Registering the inherited apartment into the heir's name at the Land Registry (Tabu) is governed by the Land Law 1969 and requires the Israeli succession order plus an apostilled, Hebrew-translated set of identity and death documents. The registration fee is modest, on the order of a few hundred shekels, but the Land Registry will reject any filing where the apostille chain or the certified translation is defective, and re-submission adds three to six weeks each time. The Israel Tax Authority must also issue clearance before transfer where any betterment exposure exists.

Running It All From France

The mechanics of doing this remotely are well established, and a French heir rarely needs to travel.

The core instrument is a power of attorney to an Israeli lawyer, signed before your notaire in France and then apostilled by the Cour d'appel under the 1961 Hague Convention. With that authority, the Israeli lawyer files the succession order application, corresponds with the Inheritance Registrar, deals with the bank, and handles the Land Registry registration on your behalf.

The supporting documents travel the other way. French civil-status records, the death certificate, and any French will or notarial act usually need to be apostilled in France and then translated into Hebrew by a translator whose signature is itself notarised in Israel. Israeli documents, in turn, must be apostilled by the Israeli Ministry of Justice and translated into French before your notaire can use them on the French side. Getting the direction and order of these translations right at the outset avoids paying for the same document twice.

Coordination between the French notaire and the Israeli lawyer is the part that makes or breaks the timeline. Each needs documents the other controls, and the two professions work to different rhythms and expectations.

What Often Goes Wrong

The classic failure is treating the French succession as the whole job.

Common Mistake: Relying on the French acte de notoriété alone to claim Israeli assets. The Israeli Land Registry and Israeli banks act only on a succession order or will execution order from the Inheritance Registrar (Rasham HaYerushot), not on a French notarial document. An heir who waits a year before discovering this then has to start the Israeli process from scratch, and in the meantime an Israeli bank may have transferred a dormant account to the State under the dormant-assets regime after ten years of inactivity, turning a simple release into a reclaim that adds several months and several thousand shekels in fees.

A second frequent problem is the apostille and translation chain. A death certificate apostilled in one country but needed in the other, translated by the wrong party or in the wrong order, gets bounced by the Israeli registry, and each correction costs weeks. The third is underestimating the French tax clock: the déclaration de succession deadline runs regardless of how slowly the Israeli order is moving, so a French heir can owe French inheritance tax on an Israeli asset they cannot yet touch.

Practical Checklist

• Treat the Israeli estate as a separate matter from the French succession, and start it early
• Establish the deceased's domicile at death, as it drives which law governs the movable estate under Section 137
• Apply for the Israeli succession order or will execution order through the Inheritance Registrar, via an Israeli lawyer under power of attorney
• Sign the power of attorney before your notaire and have it apostilled by the Cour d'appel
• Map the apostille and translation chain in both directions before paying for any of it
• Diarise the French déclaration de succession deadline independently of the Israeli timeline
• Check whether any Israeli bank account is approaching dormant status before it transfers to the State

Speak With an Israeli Attorney

A French inheritance with Israeli assets is two estates running side by side, and the Israeli order has to be obtained on its own terms before any bank or registry in Israel will move. We act for French heirs and their notaires, filing the succession order, dealing with the Inheritance Registrar and the Land Registry, and releasing Israeli bank funds, all under a power of attorney signed in France. We also coordinate with your notaire so the apostille and translation chain is done once, correctly.

Contact us for a confidential initial consultation.