A parent or relative dies in Israel, and somewhere in the estate sits a private company. Maybe it is the family business. Maybe it is a holding company that owns a single Tel Aviv apartment. Maybe it is dormant shares nobody thought about until the accountant mentioned them. For an heir living in New York, London, or Sydney, this is one of the more confusing corners of an Israeli estate, because two legal systems meet here: inheritance law decides who gets the shares, and company law decides how the shares actually move and what you can do with them once they are yours.
This guide walks through both halves. It covers the order you need before anyone will talk to you, how shares pass to heirs by transmission, how the company's own rulebook can limit what you inherit, and what tax to expect. The focus is on private limited companies, where most family shareholdings sit. Publicly traded shares held in a brokerage account follow a simpler, bank-driven route that looks more like inheriting a securities account.
1. What you actually inherit
When you inherit shares, you do not inherit the company's assets directly. You inherit a bundle of rights against the company: a slice of its profits if dividends are declared, a vote at the general meeting in proportion to your holding, a share of whatever is left if the company is wound up, and the right to inspect certain corporate records. If the late shareholder owned 100% of a company that owns an apartment in Tel Aviv, you do not become the owner of the apartment. You become the owner of the company that owns it, which is a different thing with its own tax and reporting consequences.
The share also carries whatever is attached to it. If the deceased signed a personal guarantee for the company's bank loan, that guarantee is a debt of the estate, and it does not vanish because the guarantor died. If the shares were pledged to a bank or a creditor, you inherit them subject to that pledge.
Under section 1 of the Inheritance Law, 5725-1965, the estate passes to the heirs at the moment of death. So in a strict legal sense you already own the shares from day one. The difficulty is practical: until you can prove it with an official order, the company's directors, its bank, and the Registrar will not recognise you as the holder.
2. The order you need first
Nothing happens with the shares until you hold the right court order, and which one you need depends on whether the deceased left a valid will.
- If there is no will, you apply for a succession order (tzav yerusha), which lists the legal heirs and each one's fractional share under the intestacy rules. Under sections 10 and 11 of the Inheritance Law, the surviving spouse and the children normally share the estate between them.
- If there is a will, you apply for a probate order (tzav kiyum tzava'a), which confirms the will is valid and gives it legal force.
Both applications go to the Registrar of Inheritance Matters (HaRasham LeInyanei Yerusha), a body inside the Ministry of Justice with five regional offices: Jerusalem, Tel Aviv, Haifa, Be'er Sheva, and the Central District in Lod. The application is published so that creditors and potential objectors get notice. If nobody objects within the statutory window, the Registrar issues the order. If someone does object, or the estate involves a charity, a minor, or missing heirs, the file moves to the Family Court.
3. Transmission is not a transfer
Here is the distinction that trips people up. A transfer of shares is voluntary: a living shareholder sells or gifts shares, and both sides sign a share transfer deed. Transmission is different. It happens automatically by operation of law when a shareholder dies, and there is no seller left to sign anything. The heir steps into the shares because the law put them there.
What that means in practice is that the company cannot refuse the inheritance itself. The directors cannot say "we don't want you as a shareholder" and keep the shares for the others. What they can do is insist you produce the succession or probate order before they record you, and they can apply any conditions written into the articles of association. Once you present the order, the directors pass a resolution recognising the transmission and enter your name in the register of shareholders.
Where there are several heirs, the shares are usually held jointly by the estate until the estate is divided. Many families appoint an estate administrator (menahel izavon) to hold and vote the shares in the meantime, especially where the company is an operating business that cannot sit frozen while the heirs sort themselves out.
4. Updating the registers
Two registers matter, and people confuse them. The first is internal: the company's own register of shareholders, which the directors update when they record your transmission. That internal register is what legally determines ownership. The second is the public file at the Registrar of Companies (Rasham HaChavarot), part of the Israeli Corporations Authority. For a private company, the share ownership shown publicly is refreshed mainly through the annual report (doch shnati) that every company must file, not through a real-time filing each time a share changes hands.
So the practical sequence is straightforward. Get the order, give it to the directors, get recorded in the internal register, and the change then appears in the company's next annual report. If you also become a director (for example, you inherit a controlling stake and the other shareholders appoint you to the board), a separate filing to register the new director applies.
5. What the articles can do
The company's articles of association (takanon) are its private rulebook, and they can shape what you inherit in ways that surprise foreign heirs. The provisions to look for include:
- Pre-emption rights. Before shares can be registered to an heir or sold on, the other shareholders may have a first right to buy them at a set price or a valuation formula.
- Approval of transmission. The articles may require board or shareholder approval before an heir is entered in the register. This cannot defeat the inheritance, only channel it.
- Buy-sell clauses. In companies with a shareholders' agreement, the death of a shareholder can trigger a mandatory buyout of the inherited shares, sometimes funded by a life insurance policy the company took out for exactly this event.
- Limits on who may hold shares. A professional company, for instance, may bar non-professionals from holding voting shares.
None of this is improper. It exists to stop a tightly held business from suddenly acquiring an outside co-owner the surviving partners never chose. But it means the value of what you inherit can hinge on a document the deceased signed years ago.
6. Your rights as a shareholder
Once your name is in the register of shareholders, you have the standard rights of any shareholder in an Israeli company. You can attend and vote at the general meeting in proportion to your holding. You receive dividends when the board declares them, though no shareholder can force a profitable company to distribute its profits. You can inspect core company documents. And as a minority shareholder you are protected against oppression by those who control the company.
That last point matters most for inherited minority stakes. Israeli company law treats a shareholder as owing a duty to act in good faith and to deal fairly with the other shareholders, and it gives the court power to step in when a shareholder is being squeezed out. If the people running the company freeze you out, pay themselves inflated salaries to avoid declaring dividends, or try to dilute your holding, you have remedies, including a claim for discriminatory conduct and, in serious cases, a court-ordered buyout.
7. Tax on inherited shares
Israel has no estate tax and no inheritance tax. It was abolished in 1981. Inheriting Israeli shares is not a taxable event, whether you live in Israel or abroad, and you file nothing with the Israel Tax Authority (Rashut HaMisim) simply for receiving the shares.
The tax shows up later, when you sell or when the company hands out profits.
- Capital gains on sale. When you sell the inherited shares, you pay capital gains tax. Israeli law gives you no step-up in basis. You inherit the deceased's original purchase price and purchase date, so the taxable gain runs from what the deceased paid, not from the value at the date of death. The standard rate is 25%, rising to 30% if you are a "material shareholder" holding 10% or more.
- Dividends. Distributions are taxed at 25%, or 30% for a material shareholder, and a high earner may owe an additional surtax on top.
- Non-residents. If you live abroad, a double taxation treaty between Israel and your country may cut the Israeli rate or give your home country the first claim to tax. The treaty controls, so check it before you sell.
8. Pitfalls for heirs abroad
A handful of mistakes come up again and again with overseas heirs:
- Assuming a foreign probate is enough. A grant from a court in London or New York does not, on its own, move Israeli shares. You still need an Israeli order, either a fresh application or recognition of the foreign grant.
- Letting the company drift. An operating company with nobody at the wheel after the founder dies can lose customers, breach its bank covenants, or fall behind on the annual fee. Appointing an estate administrator early keeps it running.
- Ignoring the shareholders' agreement. A buy-sell clause can convert your shares into a fixed cash sum whether you want that or not.
- Forgetting the bank guarantee. If the deceased personally guaranteed company debt, that liability is part of the estate and can eat into everything else you inherit.
- Signing a quick buyout under pressure. Surviving partners sometimes push grieving heirs to sell fast and cheap. Have the company valued first.
None of this needs to be done from a plane seat. Most overseas heirs handle the entire process through an Israeli lawyer holding a power of attorney, signing what they need to before a consul or a local notary. What does need attention is the order of operations: secure the order, get onto the register, read the rulebook, and only then decide whether to keep the shares, run the business, or sell.