UK probate does not transfer Israeli assets. A separate Israeli probate process is required — and UK Inheritance Tax may still apply.

When a loved one passes away in the United Kingdom and leaves behind property in Israel — a flat in Tel Aviv, a bank account at Bank Leumi or Hapoalim, undeveloped land in the Galilee, or investment shares — British heirs often assume that completing UK probate settles the matter. After all, the Grant of Probate or Letters of Administration has been issued by an English or Welsh court, the executors have been confirmed, and the estate administration is underway.

But here is what catches many British families by surprise: UK probate has no legal effect in Israel. It will not transfer title at the Israeli Land Registry (Tabu). It will not release funds held in Israeli bank accounts. It will not authorize the sale of Israeli real estate. To inherit Israeli assets, a completely separate Israeli probate process must be completed under the Israeli Succession Law of 1965.

We have guided numerous British families through this exact situation from our UK-focused practice. Time and again, clients tell us they had no idea a second probate proceeding was necessary — and that when they approached Israeli banks with their UK probate documents, they were turned away. The process can feel complicated and highly bureaucratic, especially for heirs trying to manage it from London, Manchester, or Edinburgh. But with proper legal representation, it is entirely manageable, and you do not need to set foot in Israel to complete it.

This guide is written specifically for British heirs. It explains the full dual-probate process, the unique tax complications that arise when UK Inheritance Tax intersects with Israeli succession law, and the practical steps we recommend to our UK clients.

Why UK Probate Does Not Work in Israel

Israel is a sovereign jurisdiction with its own succession laws. The Israeli Succession Law of 1965 governs how estates are administered and how assets are transferred to heirs — regardless of where the deceased lived or where the will was written. A UK Grant of Probate or Letters of Administration, while perfectly valid for UK assets, is a document issued by a British court and carries no legal authority in Israel.

In practical terms, this means that Israeli banks will not release funds to an executor presenting only UK probate documents. The Tabu (Israel’s Land Registry) will not transfer ownership of an apartment or plot of land based on a UK court order. Israeli investment companies will not liquidate shares. Every one of these institutions requires an Israeli court-issued document — either a Probate Order (צו קיום צוואה, where the deceased left a will) or a Succession Order (צו ירושה, where there was no will).

The requirement for a separate Israeli proceeding applies whether the deceased held Israeli citizenship, had an Israeli identity number, or was purely a British national who happened to own Israeli property. It applies whether the Israeli assets are worth £50,000 or £5,000,000.

The Israeli Probate Process for British Heirs: Step by Step

The Israeli probate process for an estate where the deceased lived outside Israel typically takes four to six months. Here is how it works when driven from the UK.

1. Gather and Prepare the Documents

The foundation of the Israeli petition is a set of properly prepared documents. If the deceased left a UK will, the original (or a certified copy) must be translated into Hebrew by a certified translator. The death certificate, marriage certificate (if relevant to the distribution), and any other official UK documents must bear an Apostille — a certification issued by the UK Foreign, Commonwealth & Development Office (FCDO) that authenticates the document for use in foreign jurisdictions. Israel is a party to the Hague Apostille Convention, so this process is straightforward, though it adds a step that many heirs are not aware of.

2. Obtain a Foreign Legal Opinion

The Israeli court requires a foreign legal opinion from a solicitor qualified in England & Wales (or in Scotland or Northern Ireland, depending on where the will was executed). This opinion must confirm that the UK will was validly executed under the law of the relevant UK jurisdiction and that there is no conflict between UK inheritance law and Israeli succession law on the matters relevant to the petition. This is a standard requirement for any foreign will submitted to an Israeli court.

3. File the Petition in Israel

The petition is filed either with the Israeli Inheritance Registrar (רשם הירושות) — which handles uncontested matters — or with the Family Court if there is a dispute. The petition must include the translated and apostilled will, the foreign legal opinion, the death certificate, the identification documents of the heirs, and details of the Israeli assets. The Israeli Inheritance Registrar publishes a notice in the official gazette, and there is a waiting period during which any interested party may file an objection.

4. Receive the Israeli Probate Order or Succession Order

Once the waiting period has expired and no objections have been filed, the court or Registrar issues the order. This document is what Israeli banks, the Tabu, and other institutions accept as legal authorization to transfer assets to the heirs.

5. Transfer the Assets

With the order in hand, the heirs’ Israeli attorney presents it to each relevant institution. Bank accounts are released, property title is transferred at the Tabu, and investments are liquidated or re-registered. If the heirs wish to sell the inherited property, that process can begin once the title has been transferred.

You do not need to travel to Israel. The entire process — from document preparation through asset transfer — can be handled remotely through an Israeli attorney acting under a properly executed Israeli Power of Attorney. We handle the vast majority of our UK client matters without the heirs ever visiting Israel.

Common Problems With UK Wills and Israeli Property

Many UK wills are drafted by English solicitors who, understandably, focus on UK assets. When the deceased also owned Israeli property, this creates several issues that can complicate the Israeli probate process.

The will may not specifically mention the Israeli apartment or land. Instead, the Israeli assets may fall under a general “rest and residue” clause — language like “I leave the remainder of my estate to…” While this is perfectly standard in UK practice, it can create ambiguity in the Israeli proceeding, particularly if the will does not identify the Israeli property by its legal description (Block, Parcel, and Sub-parcel numbers from the Tabu).

The will may not contain Israeli identification details that the Israeli court expects, such as the deceased’s Israeli identity number or Israeli passport number, even if the deceased held Israeli citizenship. This is especially common among British Jews who made Aliyah decades ago but later returned to the UK.

Some UK wills create trusts — discretionary trusts, life interest trusts, or nil-rate-band trusts — as part of tax planning for UK Inheritance Tax purposes. Israeli law treats trusts differently, and certain trust structures that are routine in UK estate planning may not be recognized or may be interpreted in unexpected ways under the Israeli Succession Law. This can require additional legal analysis and, in some cases, a modified approach to the Israeli petition.

Finally, executors named in a UK will are not automatically recognized in Israel. The Israeli court may need to appoint a separate estate administrator for the Israeli assets, particularly if the named executor is not an heir under the will. This is a procedural distinction between the two systems that surprises many UK solicitors handling cross-border estates.

UK Inheritance Tax on Israeli Assets — The Critical Tax Issue

Israel has no inheritance tax, estate tax, or death tax. This is one of the aspects of Israeli law that international clients find most favorable. However, British heirs cannot assume they are free of tax obligations simply because the assets sit in a country with no inheritance tax.

The United Kingdom imposes Inheritance Tax (IHT) at 40% on the worldwide estate of a person who was connected to the UK at the time of death, above the nil-rate band threshold. The standard nil-rate band is £325,000. If the deceased’s main home is left to direct descendants, an additional residence nil-rate band of £175,000 may apply, bringing the total threshold to up to £500,000 per person. Married couples and civil partners can transfer unused allowances to the surviving spouse, potentially doubling the threshold to £1,000,000.

The April 2025 Change: Residence Replaces Domicile

Historically, UK IHT applied to the worldwide estate of persons who were “domiciled” or “deemed domiciled” in the UK — a complex common-law concept based on the concept of permanent home and intention. From April 2025, the UK shifted to a residence-based system. Under the new Long-Term Resident (LTR) rules, anyone who has been UK tax resident for at least 10 of the previous 20 tax years is subject to IHT on their worldwide estate — including Israeli property — regardless of domicile.

This change has significant implications for British families with Israeli assets. A person who was born in Israel, lived in the UK for 15 years, and owned an apartment in Netanya is now clearly within the scope of UK IHT on that Israeli property under the new LTR test. Even after leaving the UK, the 10-year “tail” means that worldwide IHT liability continues for up to 10 years after departure. A former UK resident who returned to Israel in 2020, for example, could still be subject to UK IHT on their Israeli estate if they pass away before 2030.

Critically, there is no double-taxation treaty between the UK and Israel covering inheritance tax. While Israel imposes no inheritance tax, the absence of a treaty means there is no automatic mechanism for relief. The Israeli assets are simply within the scope of UK IHT, and the heirs must account for this in their estate planning and administration.

If the heir sells the inherited Israeli property after receiving it, Israeli capital gains tax may also apply. Israel taxes the gain on the sale of real property, including for non-resident sellers. Aharoni Law Firm has extensive experience helping non-resident heirs reduce or eliminate Israeli capital gains tax through applicable exemptions and reliefs. This is a separate issue from UK IHT, but both must be considered as part of the overall plan.

We strongly advise British heirs to consult a UK tax advisor or solicitor with IHT expertise before proceeding with the Israeli probate, so that the full tax exposure is understood and any available planning opportunities can be identified.

Should British Families Have a Separate Israeli Will?

In many cases, the answer is yes. Having a separate Israeli will that covers only Israeli assets can significantly simplify the inheritance process.

A properly drafted Israeli will, written in Hebrew and executed in accordance with the Israeli Succession Law, eliminates the need for translation, Apostille, and foreign legal opinion — three requirements that add months to the process and create opportunities for complications. The Israeli will is filed directly with the Inheritance Registrar and proceeds through the standard Israeli probate timeline without the additional hurdles that a foreign will introduces.

The key requirement is coordination. If a separate Israeli will exists, the UK must explicitly exclude Israeli assets from its scope. Otherwise, the two wills may conflict, and the Israeli court may need to determine which takes priority — a scenario that creates delay, expense, and uncertainty. This is where working with a law firm that understands both systems is essential.

As part of our estate planning services, Aharoni Law Firm prepares Israeli wills for international clients, specifically designed to complement their existing UK (or other foreign) wills. This is one of the most effective steps a British family can take to protect their Israeli assets and ease the burden on future heirs.

What We Recommend to Our UK Clients

Based on our experience serving British families from our UK-focused practice, here is the guidance we most frequently provide:

1. Do not assume UK probate covers Israel. If the estate includes any Israeli assets — property, bank accounts, investments, or land — a separate Israeli probate is required. Begin the Israeli process as soon as the UK Grant of Probate is issued (or earlier, in consultation with your Israeli attorney), as the two proceedings can run in parallel.
2. Assess UK Inheritance Tax exposure early. Under the post-April 2025 Long-Term Resident rules, most UK-connected deceased persons will have worldwide IHT liability that includes Israeli assets. Engage a UK tax advisor before distributing any assets, and certainly before selling Israeli property.
3. Prepare your documents properly from the outset. Obtain the Apostille from the FCDO early. Commission the certified Hebrew translation of the will. Arrange for the foreign legal opinion from a qualified solicitor. Missing or improperly prepared documents are the single most common cause of delay in cross-border Israeli probate matters.
4. Consider a separate Israeli will. If your family owns Israeli property and does not yet have a dedicated Israeli will, this is one of the most impactful planning steps you can take. It saves your heirs months and reduces the complexity and cost of the eventual probate.
5. Engage an Israeli attorney early. An Israeli lawyer at our firm who understands cross-border estates can coordinate with your UK solicitor, manage the Israeli probate remotely through a Power of Attorney, and handle the asset transfer — including navigating the banking regulations that British heirs routinely describe as complex and bureaucratic.

A Note From Our Founder, Rahav D. Aharoni, Adv.

At Aharoni Law Firm, we have made cross-border Israeli inheritance law one of our core practice areas because we have seen firsthand how difficult this process can be for families who are not prepared. British families, in particular, face a unique combination of challenges: the dual-probate requirement, the interplay between UK Inheritance Tax and Israel’s tax-free succession system, the Apostille and translation requirements, and the practical difficulty of dealing with Israeli institutions from thousands of miles away.

We serve UK clients through our dedicated United Kingdom practice, and we handle these matters regularly. Our goal is to make the process as straightforward as possible — so you can focus on your family while we handle the legal and bureaucratic complexities.

If you have inherited Israeli property or expect to inherit Israeli property in the future, I encourage you to reach out for an initial consultation. Understanding your situation early is always better than scrambling after the fact.

— Rahav D. Aharoni, Adv.

Founder, Aharoni Law Firm

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