Middle East.

The Middle East presents the most distinctive succession landscape of the four regions. Personal-status law is generally faith-based, with Sharia governing succession for Muslim decedents in most jurisdictions and separate provisions applying to non-Muslims. The Sharia framework imposes faraid — fixed inheritance shares for specified heirs — typically limiting testamentary disposition to one-third of the estate, with the remainder passing to compulsory heirs in fixed proportions.

Several jurisdictions (UAE, Saudi Arabia, Bahrain) have introduced civil personal-status frameworks for non-Muslim residents, including the DIFC and ADGM common-law enclaves enabling testamentary freedom for non-Muslim expatriates. Memoranda for this region are presently in development.

• Sharia faraid (compulsory shares) limiting testamentary disposition to one-third for Muslim decedents.
• DIFC and ADGM Common-Law Wills Registries enabling non-Muslim expatriate testamentary freedom in the UAE.
• Personal-status law conflicts where decedent and beneficiaries belong to different faiths.
• Real-property restrictions on foreign ownership and succession across most GCC jurisdictions.
• The general absence of estate or inheritance tax in GCC jurisdictions.
• Repatriation of inheritance proceeds under foreign-exchange-control regimes (where applicable).
• Cross-border Muslim succession involving Sharia faraid and a second non-Sharia jurisdiction’s forced-heirship or testamentary-freedom regime.
• Recognition of foreign wills in Sharia-jurisdiction courts and probate procedures.