Estate Planning between Switzerland and Israel

Estate planning between Switzerland and Israel is complex – differing inheritance laws, procedures, and tax rules require careful cross-border preparation. While Switzerland’s system protects close relatives from complete disinheritance through statutory forced heirship, Israel grants absolute testamentary freedom, supplemented only by socially motivated maintenance claims. Testamentary options, the handling of real estate, the recognition of probate certificates, and the role of trusts and executors differ significantly between the two jurisdictions.

Anyone holding assets in both countries must also be aware that Swiss probate certificates are not recognized in Israel, requiring a separate local procedure. Tax considerations – especially concerning real estate – as well as the correct choice of applicable law and jurisdiction clauses can be crucial in protecting heirs from financial and legal disadvantages.

This guide highlights the key differences and provides practical insights on how to transfer wealth securely, tax-efficiently, and in line with personal wishes – in close coordination with experts in both countries.