United Arab Emirates (AE)
The United Arab Emirates is a federation of seven emirates — Abu Dhabi, Dubai, Sharjah, Ajman, Umm Al Quwain, Ras Al Khaimah, and Fujairah — that has transformed from a pearl-diving and fishing economy into one of the world's most modern and cosmopolitan nations within a single generation.
Estate & Inheritance in United Arab Emirates
Wills, intestacy, inheritance tax, and cross-border estate planning for expats.
Estate planning in the UAE is one of the most important but commonly overlooked aspects of expatriate life. By default, UAE law applies Sharia inheritance principles to all residents, including non-Muslims, unless a will has been registered with the appropriate authority. This means that without a registered will, your UAE assets (bank accounts, property, investments, vehicles) will be distributed according to Islamic inheritance rules, which may bear no resemblance to your wishes. UAE banks freeze accounts immediately upon notification of a death, making it critical to have a registered will in place. Non-Muslim expatriates should register a DIFC or Abu Dhabi Judicial Department (ADJD) will as a high priority.
Intestacy — What Happens Without a Will
Without a registered will, UAE Sharia law applies to all UAE assets regardless of nationality or religion. Under Sharia: a surviving wife receives 1/8 of estate (if there are children) or 1/4 (if no children). Sons receive twice the share of daughters. Non-family members receive nothing. Non-Muslim partners (unmarried) have no legal claim. The process is handled by the Personal Status Court and can take months to years. Bank accounts remain frozen throughout probate proceedings — this can cause severe financial hardship for surviving family members.
Types of Valid Will
DIFC Will
DIFC Wills Service Centre WillA registered will through the Dubai International Financial Centre (DIFC) Wills Service. Available to all non-Muslim expatriates. The DIFC uses English common law principles — your will is interpreted in accordance with your intentions, not Sharia. Covers all Dubai and UAE-wide assets including property, bank accounts, shares, business interests, and guardianship of minor children.
Legally enforceable across the UAE. Internationally recognised.
The DIFC Will is the gold standard for non-Muslim expats in the UAE. Can be done online via wills.difc.ae. Should be reviewed and updated after major life changes (new children, property acquisition, divorce). DIFC courts administer the estate — typically 3–6 months for uncomplicated estates.
Abu Dhabi Judicial Department (ADJD) Will
ADJD Non-Muslim WillWill registration through the Abu Dhabi Judicial Department for non-Muslim expatriates. Covers assets located in Abu Dhabi. Similar in concept to DIFC Will but administered by Abu Dhabi courts. If you have assets in both Dubai and Abu Dhabi, you may need separate registrations or a comprehensive will covering both.
Enforceable for Abu Dhabi assets. Cannot be used for assets in other emirates without additional registration.
Good option if you are primarily Abu Dhabi-based. For UAE-wide asset coverage, DIFC Will is more comprehensive.
Home Country Will with UAE Recognition
Foreign Will (attested and notarised)A will made in your home country can sometimes be used in the UAE if it is properly attested, apostilled, translated into Arabic, and presented to UAE courts. However, this approach is unreliable — UAE courts may still apply Sharia to UAE assets regardless of a foreign will.
Uncertain — UAE courts have discretion. Not recommended as the primary solution for UAE assets.
Do not rely solely on a home-country will to protect UAE assets. The DIFC Will specifically overrides the default Sharia succession for non-Muslims. A home-country will cannot achieve this with certainty.
Islamic Will (Wasiyyah)
الوصيةA will made in accordance with Islamic Sharia law. Standard for Muslim residents. Validated by the Personal Status Court. Can direct up to 1/3 of estate to non-heir beneficiaries.
Fully enforceable under UAE law for Muslim residents.
Muslim expatriates should ensure their Wasiyyah is registered. The default Sharia distribution may still not match your exact wishes — a registered Wasiyyah allows you to direct the discretionary 1/3 of estate.
Forced Heirship
Under UAE Sharia law (for Muslim residents or where no registered will exists), forced heirship rules apply: prescribed shares are mandated for certain relatives (spouse, children, parents). Only up to 1/3 of the estate can be freely directed to others. For non-Muslims with a registered DIFC Will, forced heirship does not apply — you can leave your UAE assets to anyone.
EU Succession Regulation (Brussels IV)
The EU Succession Regulation (Brussels IV, 2015) does not apply in the UAE — the UAE is not an EU member state. EU citizens in the UAE should not assume EU succession rules govern their UAE assets. Your UAE assets will be subject to UAE law unless a registered UAE will (DIFC/ADJD) specifies otherwise.
Inheritance Tax
There is no inheritance tax in the UAE. No estate duty, no death duties, no capital gains tax on inherited assets. This is one of the significant financial advantages of UAE residency. However, probate costs (court fees, lawyer fees, trustee fees) do apply and can be 2–5% of estate value.
| Relationship | Tax-Free Allowance | Tax Rate (above allowance) |
|---|---|---|
| All heirs (spouse, children, parents, others) | Unlimited — no inheritance tax | 0% |
No inheritance tax at federal or emirate level. Probate/administration costs apply. For overseas assets inherited from UAE residents, inheritance tax laws of the country where those assets are located apply.
Cross-Border & Multi-Country Estates
UAE residents often have assets in multiple countries (UK property, home-country bank accounts, investments). Your home country's succession laws apply to those assets. Ensure you have appropriate wills in each country where you hold significant assets. For UK property, a UK will is required. For EU assets, consider whether EU Succession Regulation allows you to elect home-country law. Seek cross-border estate planning advice from a specialist.
Certificate of Inheritance
The UAE does not issue a single comprehensive inheritance certificate. Each asset class requires separate court orders or transfer applications. For DIFC Will estates, the DIFC Wills Service appoints an executor who has authority to deal with UAE assets. For Sharia estates, the Personal Status Court issues a determination of heirs. Banks, property registries, and vehicle licensing departments each require separate applications with court orders.
Will Registration
DIFC Wills Service Centre — wills.difc.ae. Abu Dhabi Judicial Department — adjd.gov.ae. Both are searchable by the executor after death. There is no single national will registry in the UAE. It is important to tell your executor where your will is registered.
Living Will & Healthcare Power of Attorney
No legal framework for a living will or advance directive specifically governs UAE medical decisions. In practice, UAE private hospitals will generally consult next of kin on major decisions if the patient is incapacitated. For expats with specific medical preferences, carrying a notarised document stating your wishes and sharing it with your GP and family members is advisable, though its legal enforceability is limited.
Useful Links
Estate & Inheritance
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