Succession: IsraelGermany

Case complexity: low. The testator resides in Israel, the heir resides in Germany.

Which law decides who gets what

Under Israel rules, money, accounts and shares are inherited by the law of the country where the person lived, while real estate follows the law of the country where it physically sits.

Who the law forces you to include

Israel: No classic forced share; maintenance for dependants is provided out of the estate.

Where tax arises

Israel: No inheritance tax.

How it is recognised and processed

Testator and heir in different countries — documents will need cross-jurisdiction recognition and legalisation (apostille, translation, sometimes a repeat procedure).

What to set up in advance

Will with a choice of applicable law

Private foundation

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This is general guidance, not legal advice. The rules are simplified; confirm current rates and details with a lawyer.

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