Can my UK solicitor handle my Israeli matter, or do I have to instruct an Israeli lawyer?

British families running an Israeli estate, a property sale or a tax dispute nearly always start with the solicitor they already trust in London, and that is a reasonable instinct. It stops being reasonable at the point where somebody has to file something in Israel. The line Israeli law draws is not about competence or seniority. It is about which body licensed you, and it is drawn in a part of the Bar Association Law that most foreign lawyers have never read.

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Detailed Answer

The Bar Association Law 5721-1961 reserves the practice of Israeli law to members of the Israel Bar Association, and it deals separately with lawyers qualified elsewhere. Section 98A defines a foreign lawyer as a person holding a licence to practise law outside Israel, whose centre of professional activity as a lawyer is outside Israel, and who is registered in the register of foreign lawyers maintained by the Israel Bar Association. Section 98B(a) then fixes the boundary: a foreign lawyer may provide legal services in matters of foreign law only, and may not provide legal services on questions of Israeli law, which may be given only by the holder of a valid Israeli licence. Foreign lawyers and foreign law firms that actually operate in Israel, rather than advising from abroad, register with the Bar under the mechanism in Sections 98F and 98I. Everything that Israeli law reserves to an advocate sits on the Israeli side of that line, and it is a longer list than most foreigners expect: appearing before the courts, the Family Court, the Labour Court and the Execution Office, filing an application with the Inheritance Registrar, signing and submitting a real estate transaction to the Land Registry and the Land Taxation authority, and giving advice on Israeli legal rights. A separate question is full admission. A lawyer qualified in England who wants an Israeli licence rather than foreign-lawyer status goes through the Bar's own route, which involves recognition of the foreign qualification, examinations in defined Israeli law subjects and, depending on the applicant's experience, a period of internship, all of it conducted in Hebrew. That is a genuine career decision rather than a formality, and it is not the answer for a solicitor handling one Israeli file.

In practice the workable structure is two lawyers and one client, and it works well when the roles are set at the start. The Israeli advocate takes conduct of everything that touches an Israeli authority and signs it. The English solicitor keeps the parts that are English law, which in a typical cross-border estate means the grant of probate, the domicile analysis, inheritance tax and the distribution to beneficiaries, and in a property matter means the UK tax treatment of the proceeds. Both sides need one document to make it function: a power of attorney in favour of the Israeli lawyer, signed before a notary and apostilled, since Israeli registries will not act on an instruction relayed by a foreign firm. Where the signature is taken in Israel the notarial fee for authenticating it is fixed by regulation at NIS 197 for the first signatory and NIS 77 for each additional one, and the equivalent step in England is notarisation plus an FCDO apostille. Three points prevent the common failures. Agree in writing who is responsible for Israeli deadlines, because Israeli objection and appeal periods are short and a file where each lawyer assumes the other is watching the clock is the classic way a right is lost. Do not let a foreign firm hold the Israeli funds; Israeli trust account rules apply to the Israeli lawyer and that is where sale or estate proceeds should sit. And confirm the Israeli lawyer's own position independently, since your recourse if something goes wrong runs through the Israel Bar and the Israeli courts, as our answer on complaining about or suing an Israeli lawyer from abroad explains.

In Practice: Section 98A of the Bar Association Law 5721-1961 defines a foreign lawyer by reference to a foreign licence, a centre of professional activity outside Israel and registration in the Israel Bar Association's register of foreign lawyers, and Section 98B(a) limits that lawyer to matters of foreign law only. Foreign firms operating in Israel register under Sections 98F and 98I. Filings with the Inheritance Registrar, the Land Registry, the Israel Tax Authority and every Israeli court must be made by an Israeli advocate acting under a notarised and apostilled power of attorney, for which the Israeli notarial authentication fee is NIS 197 for the first signatory and NIS 77 per additional signatory. Allow 2 to 4 weeks for the power of attorney to be executed abroad and reach Israel in usable form.

When to Consult a Lawyer

• Your foreign firm has already sent correspondence to an Israeli authority in its own name. Israeli registries and tax offices generally will not act on it, and the time lost is usually measured against a deadline that has been running throughout.
• A deadline is close. Objection periods before the Israeli tax authorities, the Inheritance Registrar and the municipalities are measured in days and weeks rather than months, and they are not extended because the client's own lawyer is abroad.
• Money is about to move. Sale proceeds, estate funds and deposits belong in an Israeli lawyer's trust account subject to Israeli rules, and an arrangement that routes them elsewhere creates problems with the Israeli bank as well as with the regulator.

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Speak With an Israeli Attorney

We act as Israeli counsel alongside solicitors and attorneys abroad, take conduct of the Israeli filings, and set up the power of attorney so the two sides of the file work as one.

Contact us for a confidential initial consultation.