Which law applies to an international inheritance between France and Israel?

The law applicable to an international succession determines who the heirs are and their respective rights.

This depends on the deceased's last place of residence and the date of death.

To illustrate our point, let us take the example of the estate of a deceased person whose last domicile (main residence) was established in France and which includes real estate and personal property in Israel.

The question then arises as to which law applies to the settlement of his estate.

To do this, it is necessary to refer to the date of the deceased's death, as the French and European legal rules applicable to the inheritance depend on it.

Thus, before the entry into force in France of European Regulation No. 650/2012 in August 2015 (which now only concerns the settlement of the estate of a person who died before that date), the rules of private international law stipulated that:

The law applicable to real estate (land and buildings) was that of the location of the real estate (therefore Israeli law in our example).

And the law applicable to movable property (furniture, bank accounts, motor vehicles, boats, shares, stocks, etc.) was that of the deceased's last domicile (therefore French law in our example).

However, since the entry into force in France on 17/08/2015 of European regulation no. 650/2012 of 04/07/2012, relating to the rules applicable to national successions, the rules have changed; therefore, only the provisions of the law of the last place of residence of the deceased will apply with regard to the distribution of his estate in France and abroad to the entirety of the deceased's assets.

Therefore, in our example, the provisions of French law will apply to the division of the entire estate of the deceased, including that of his real estate in Israel.

Heirs wishing to register real estate located in Israel and included in the deceased's estate in their names must submit their application to the Israeli courts.

However, Israeli courts will be required to apply French law and, to do so, will require an expert opinion on foreign law written by an Israeli lawyer notary who is an accredited expert in French and European law.

Me. Maayan ABIHSSIRA, Lawyer & Notary

The preceding information is for general guidance only, current as of July 2025, and should not be considered a substitute for individualized legal advice. The rules and rates are based on Israeli and French law in effect at the time of writing.