In brief
In some countries the heirs’ first deadline comes quickly: in Portugal the tax declaration is filed by the end of the third month after the month of death, in Greece an inheritance can be renounced within 4 months (one year when the deceased’s last residence was abroad), and in Ukraine an inheritance is accepted within 6 months. In the first 90 days, it is advisable to obtain an inheritance order or probate order in Israel, obtain an apostille and translations, clarify which law applies and protect the property. There is no inheritance tax in Israel, but the property has implications for reporting and tax later on.
Key takeaways
- 1The deadlines in the country of the property start on the day of death, not on the day you received an inheritance order in Israel, so check them immediately.
- 2In most countries you need an Israeli inheritance order or probate order, a death certificate and proof of kinship, with an apostille and a certified translation.
- 3In most cases there is no need to travel: you act through a notarial power of attorney with an apostille and translation, or at a consulate.
- 4There is no inheritance tax in Israel, but a future sale of the property is subject to capital gains tax, and a property you have inherited may require you to file an annual return.
- 5In the interim period, keep paying property tax, insurance and ongoing charges, and secure the property and the documents in it.
Why are the first 90 days in particular important?
Because in some countries the first statutory deadline falls within this period or close to it, and because the Israeli procedure that precedes it takes time. Many heirs wait for an inheritance order in Israel and only then check what is required in the country of the property, and then discover that a deadline for a declaration, for accepting the inheritance or for renouncing it is already close.
This guide does not replace the detailed guides for each country, such as the guide on inheriting property in Romania or the guide on inheritance and gifts in Greece. Its purpose is to give an order of actions for the first months, and to bring the urgent deadlines together in one place.
What urgent deadlines are there in each country?
The table brings together the main deadlines we found in the sources, as of October 2026. The relevant deadline sometimes depends on the law applicable to the succession, on the place of residence of the deceased and of the heirs, and on whether there is a will, so every deadline is checked with a professional in the country of the property.
| Country | Urgent deadline | What else is worth knowing |
|---|---|---|
| Romania | When Romanian law applies: acceptance or renunciation of the inheritance within one year of death (article 1103 of the Civil Code); anyone who has not acted is treated as having renounced | There is no tax on the transfer if the procedure before the notary is completed within two years of death; after that, 1% of the value of the assets |
| Greece | Renunciation of the inheritance within 4 months, or one year when the deceased’s last residence was abroad or the heir lives abroad; inheritance tax declaration within 9 months, or one year in similar situations | For deaths from 16 September 2026 a new inheritance law applies (5303/2026), so the updated rules are checked |
| Cyprus | Declaration of the deceased’s assets to the Tax Department within 6 months of death | There has been no inheritance tax since 2000; the procedure usually goes through the District Court and an administrator of the estate |
| Bulgaria | Inheritance tax declaration within 6 months of death, and for an heir abroad 6 months from the day he or she learned of it | A spouse and relatives in the direct line are exempt from inheritance tax; the procedure is conducted at the municipality and in court, not before a notary |
| USA | Form 706-NA for federal estate tax within 9 months of death, with the option to request an extension | For a nonresident the effective exemption is only USD 60,000; transfer of the property usually goes through a probate procedure in the state where it is located |
| Italy | Inheritance declaration to the Agenzia delle Entrate within 12 months of death | The right to accept the inheritance is time-barred 10 years after death; inheritance tax depends on kinship and value |
| Portugal | Tax declaration (participação) by the end of the third month after the month of death, with the option of an extension of up to 60 days for good cause | A spouse, descendants and parents are exempt from stamp duty on inheritance; others pay 10% |
| Ukraine | Acceptance of the inheritance by application to a notary within 6 months of death; anyone who has not applied is treated as not having accepted | The courts are divided on whether the martial law regulations change the period, so act within the 6 months |
Romania, Greece, Cyprus, Bulgaria, Italy and Portugal are bound by the European Succession Regulation 650/2012. Under it, as a rule the law of the deceased’s habitual residence on the date of death applies, even when that is a country outside the EU, unless the deceased chose the law of his or her nationality in a will. For a deceased who lived in Israel, the starting point is therefore sometimes Israeli law, and this also affects the deadlines.
What do you do in each month of the first 90 days?
The work can be divided into three stages, some of which run in parallel. This order suits most countries, and in each country the local requirements are added.
| Period | In Israel | In the country of the property |
|---|---|---|
| Days 1 to 30 | Death certificates, locating a will, filing an application for an inheritance order or probate order, and a list of all the assets abroad | Clarifying what is recorded in the land registry extract, who holds keys, which accounts and ongoing payments exist, and what the first statutory deadline is |
| Days 31 to 60 | Receiving the order, apostille, translations, and a power of attorney from the heirs to a representative in the country of the property | Approaching a local notary or lawyer, obtaining a local tax number for the heirs where required, and checking property tax debts |
| Days 61 to 90 | Coordinating with an accountant on the implications in Israel, and checking whether an obligation to file an annual return has arisen | Opening the local procedure or filing the first declaration, and in Portugal filing the tax declaration by the end of the third month after the month of death |
Which documents need to be prepared in Israel?
In most countries you will need the same basic set, with adjustments. The main difference is the language of the translation and whether the country of the property accepts the Israeli order as it is or requires an additional local procedure.
- Death certificate, with an apostille and a certified translation into the language of the country.
- Inheritance order or probate order from the Registrar of Inheritance Affairs, or from the Family Court when there is an objection. The Ministry of Justice offers a digital order with an apostille for use in countries that are party to the Hague Convention.
- The will, if there is one, and any document in which the deceased chose the law to apply to his or her succession.
- Proof of kinship: birth and marriage certificates proving the relationship between the deceased and the heirs.
- Property documents: the purchase contract, an up-to-date extract from the land registry, and for property held through a company, the company documents.
- The heirs’ passports, and a local tax identification number for each heir when the country requires it (NIF, AFM, codice fiscale).
- A notarial power of attorney from the heirs to a representative in the country of the property, with an apostille and translation.
The procedure in Israel includes publication of the application and a period for filing objections, so it takes time even when there is no dispute. It is advisable to file the application as early as possible, and in parallel to begin the clarification in the country of the property. When there is an objection, the file is transferred to the Family Court, and the procedure takes longer.
Do you need to travel to the country of the property?
In most cases, no. The procedure before the notary or in the local court can be conducted through a notarial power of attorney signed in Israel, with an apostille and translation, or by signing at the consulate of the country of the property. It is important that the power of attorney expressly authorises the required acts: accepting or renouncing the inheritance, signing declarations, registration, and later also sale, if that is the intention.
Some acts may require attendance in person or remote identification, such as opening a local bank account or obtaining a tax number in certain countries. When there are several heirs, they can all sign a power of attorney to the same representative, which avoids a situation in which one heir’s signature holds everyone up.
What needs to be done with the property itself in the interim period?
Protect it and its value. The property continues to accumulate debts even when no one is registered as its owner: local property tax, building committee or owners’ association fees, utility bills and insurance. An accumulated debt usually comes to light on the day of sale or registration, when the notary requires confirmation that there are no debts.
- Make sure the insurance is in force and that the policy covers a vacant property.
- Check whether there is a tenant, a lease and a deposit, and who collects the rent.
- Collect keys, codes and documents located in the property.
- Do not sell, re-let or sign on behalf of the estate before it is clear who is authorised to do so.
What does the inheritance mean in terms of tax in Israel?
There is no inheritance tax and no estate tax in Israel, so receiving the property does not in itself give rise to tax in Israel. Inheritance tax charged by the country of the property, if there is one, is the tax cost of the transfer itself. But the property has implications in Israel later on, and some of them begin already in the year of death.
- Future sale: a sale of the property by the heirs is subject to capital gains tax in Israel, with a credit for the tax in the country of the property, and reporting on Form 1399 within 30 days. As a rule, the heir steps into the shoes of the deceased with regard to the acquisition date and cost. When the deceased was not an Israeli resident, check with an accountant whether different rules apply.
- Income from the property: under the Income Tax Ordinance, the income of the estate from the date of death is treated as income of the heirs according to their shares. Rent from the property is reported in Israel, with a choice between the 15% route and marginal tax with a credit.
- Obligation to file an annual return: a property you have inherited is included in the value of your foreign assets, and may cross the threshold that requires an annual return.
- Foreign tax on the inheritance: it is advisable to check with an accountant whether it can be taken into account in Israel, because Israel does not levy an inheritance tax against which it could be offset.
When some of the heirs are not Israeli residents, the tax on them is determined by their country of residence, and the deadlines in the country of the property may be different for them. In Greece, Romania and Bulgaria, for example, the place of residence of the heir or of the deceased affects the deadline.
What to do now and how we assist
The first step is to list all the assets abroad, the country of each asset and the first statutory deadline that applies to it, and to file the application for the order in Israel. We help build the list of deadlines, prepare the documents in Israel with an apostille and translation, draft a power of attorney that meets the local requirements, and coordinate with a notary or lawyer in the country of the property and with your accountant in Israel.
What is stated here is general information as of October 2026, and is not legal or tax advice for a specific case. Deadlines and tax rates change, and they depend on the law applicable to the succession, on the place of residence of the deceased and of the heirs and on whether there is a will. Before taking any action, check the deadline with a professional in the country of the property.
Frequently asked questions
Within how long must an inheritance of property in Romania be accepted?
When Romanian law applies to the succession, an heir must accept or renounce the inheritance within one year of the date of death, and anyone who has not acted is treated as having renounced. When another law applies, for example Israeli law, the deadline is checked with the notary. For tax purposes, completing the procedure within two years of death exempts you from the transfer tax.
Is an Israeli inheritance order valid abroad?
It is usually used, with an apostille and a certified translation, but some countries also require a local procedure, such as a certificate of inheritance before a notary in Romania or a probate procedure in the USA. The Ministry of Justice offers a digital order with an apostille for use in countries that are party to the Hague Convention.
Do I need to fly in order to inherit property abroad?
In most cases, no. You can act through a notarial power of attorney signed in Israel, with an apostille and translation, or at the consulate of the country of the property. Some acts, such as opening a bank account, may require attendance in person or remote identification.
Do I pay tax in Israel on property I inherited abroad?
Not on the inheritance itself, because there is no inheritance tax in Israel. Rent from the property is reported in Israel, and a future sale is subject to capital gains tax with a credit for the tax in the country of the property, and reporting within 30 days.
What is the shortest deadline worth knowing about?
Of the countries in the guide, in Portugal the tax declaration is filed by the end of the third month after the month of death, and in Greece renunciation of an inheritance is possible within 4 months in the ordinary case. In Ukraine, acceptance of the inheritance is within 6 months.
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- Romania - Codul civil, art. 1103 (termenul de opțiune succesorală)
- Greece - Law 5219/2025, article 85 (Taxheaven)
- IRS - Some nonresidents with U.S. assets must file estate tax returns
- Agenzia delle Entrate - Dichiarazione di successione
- Portal das Finanças - Código do Imposto do Selo, artigo 26
- PwC Worldwide Tax Summaries - Ukraine, Individual: Other taxes
- Innovires - Inheritance in Bulgaria
- The Legal 500 - Cyprus inheritance tax facts
- Regulation (EU) No 650/2012 on succession, chapter III
- gov.il - digital inheritance order with apostille
- Kol Zchut - objection to a probate order
- PwC Worldwide Tax Summaries - Israel, Individual: Other taxes