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Executing a UK will that covers all of the testators’ assets, including assets outside of the UK, is standard practice in English legal practice.

When it comes to assets that a person holds in Israel, no disposition can take place before a Probate is granted by the Israeli Probate Registry or the courts. There can be no disposition regarding any asset. The banks will not pay out any money, even in cases of jointly owned accounts, except in where a survivorship clause was included when the account was set up.

S.136 of the Israeli inheritance act 1965 grants exclusive jurisdiction to the Israeli courts for granting probe or letters of administration for a non-Israeli who left property in Israel.

Beneficiaries and/or executors of a will need to apply to the Israeli court and will need to produce the original will. It will be difficult to comply with this requirement since there will only be one original copy of the will in the UK and the will will be required for local Probate procedures, which can take a significant amount of time. When UK inheritance tax is due, the issue becomes more urgent.

A separate Israeli Will can be executed to bypass this burden. Only the assets owned in Israel will be affected by the Israeli Will, not assets owned in any other jurisdiction.

The Israeli will help to save time, costs, and provide legal certainty in the way the probate will take place in Israel. It is highly advisable to appoint an Israeli probate lawyer as the executor of a substantial or complex estate in Israel.

Written by Eli Rosenberg, LL.B, an Israeli inheritance lawyer permanently residing in London, expert in Israeli Probate and Property law.

The information in this article is for general information purposes only, and it should not be taken as legal advice. If you have specific questions, you should seek legal advice.

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