Does an Israeli succession order cover assets located outside Israel?

An Israeli succession order does not itself distribute a specific list of property. It declares who the heirs are and their shares under intestacy, while a probate order (tzav kiyum tzava'a) validates a will. Once issued, the order carries legal force within Israel and lets heirs transfer Israeli bank accounts, company shares, and real estate at the Land Registry. Section 137 of the Succession Law 5725-1965 provides that succession is governed by the law of the country where the deceased was domiciled at death, subject to the rule that rights in Israeli immovable property always follow Israeli law. Where the deceased was domiciled abroad, the Registrar or Family Court can still issue an order confined to Israeli assets while applying the relevant foreign succession law to identify the heirs. You can read more in the full guide to succession orders in Israel.

For a foreigner who dies owning a Tel Aviv apartment plus a home and accounts in their own country, the Israeli order is typically obtained only for the Israeli assets, and a separate grant of probate or its local equivalent is needed abroad. Foreign banks and land registries rarely act on an Israeli order without their own recognition process. Where a foreign grant already exists, it can sometimes be recognized in Israel instead of applying afresh, provided it is apostilled and translated. Families with cross-border estates should map which assets sit in which jurisdiction at the outset, because two parallel processes on different timelines can delay access to funds. The interaction between an Israeli estate and a foreign will is a common source of confusion worth clarifying early.

From the full guide: Succession Orders in Israel: What They Are and How to Obtain One

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