The situation is common in Jerusalem: someone made a will in France years ago, and later bought a flat in Israel — or the other way round. The question that arises then is not only whether the will is valid, but how it is actually given effect over assets located in another country.
Two distinct questions
The first is which law governs the estate, which depends on connecting factors — the deceased’s habitual residence, where the assets are, any choice made by the testator. The second is procedural: even where a foreign will is capable of taking effect, giving it effect in Israel means an application to the competent authority, with the documents, translations and legalisations that entails.
The difficulties we see rarely concern the substance. They come from the details: a will nobody can find, heirs who do not all know one another, an asset described in terms that no longer match its current designation, or two successive wills with no clarity as to which prevails. Each of these is far easier to resolve while the testator is alive than afterwards.
There is no single answer: it depends on the family situation, the place of residence, the nature of the assets and the date of the documents. A careful reading of the existing papers is often enough to tell whether something needs doing or whether matters are in order.
This article is general information, not advice or a recommendation, and reading it creates no lawyer-client relationship. If you have a will made abroad and assets in Israel, let us discuss your situation.