Saudi Arabia.

The Kingdom of Saudi Arabia operates a Sharia-based succession system founded on the Hanbali school of Islamic jurisprudence. The Personal Status Law of 2022 (Royal Decree M/73, in force 18 June 2022) codified previously uncodified Sharia rules into statutory form — a major modernization of family and succession law. Sharia faraid imposes fixed compulsory shares on heirs (sons receiving twice the share of daughters, with specific shares for spouse, parents, and other relatives), with testamentary disposition (wasiyyah) limited to one-third of the estate.

The Civil Transactions Law of 2023 (Royal Decree M/191) further codified general civil-law principles, marking the most significant structural reform of Saudi private law. Saudi Arabia imposes no inheritance, estate, or gift tax. Foreign ownership of real property remains constrained, with succession of foreign-held assets generally requiring conversion or repatriation. The Sharia courts (al-Mahakim al-Shar’iyyah) supervise contested succession.

The memoranda in this series address the recurring fact patterns in Saudi cross-border estate planning — including the post-2022 codified faraid regime, succession of family-business shares, real-property foreign-ownership constraints, recognition of foreign wills before Saudi courts, repatriation of inheritance proceeds, and the absence of estate-tax treaties with Canada and the United States.