01Applicable law
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.
Succession: Israel → Portugal
What happens to the estate
Case complexity: low. The testator resides in Israel, the heir resides in Portugal.
Testator
Citizen of Israel
Resident of Israel — the centre of life.
Heir
Resident of Portugal
The estate stays in one jurisdiction — a simpler process.
0%
inheritance tax in Israel — but assets are taxed where they sit.
02Forced heirship
Who the law forces you to include
- Israel: No classic forced share; maintenance for dependants is provided out of the estate.
03Tax
Where tax arises
- Israel: No inheritance tax.
04Recognition
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).
05What to set up
What to set up in advance
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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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