Bahrain.

Bahrain operates a complex layered succession system reflecting the Kingdom’s mixed Sunni and Shi’a Muslim population. The Personal Status Law of 2017 codifies succession rules for Sunni Muslims, while the partial Personal Status Law of 2009 covers some Shi’a personal-status matters; the broader Shi’a community continues to rely on uncodified juristic interpretation. Both Sunni and Shi’a regimes impose Sharia faraid compulsory shares, with testamentary disposition limited to one-third of the estate.

For non-Muslim residents — Bahrain has substantial Christian, Hindu, and other expatriate communities — the Civil Code 2001 and general civil-procedure provisions supply default succession rules, with foreign wills and applicable foreign succession law generally recognized through Bahrain’s private-international-law framework. Bahrain imposes no inheritance, estate, or gift tax. The High Sharia Court of Appeal hears Sunni and Shi’a succession matters; the Civil High Court hears non-Muslim matters.

The memoranda in this series address the recurring fact patterns in Bahraini cross-border estate planning — including the Sunni-Shi’a regime distinction, non-Muslim succession under the civil framework, real-property succession constraints for foreign ownership, recognition of foreign wills before Bahraini courts, the role of Bahrain as a regional financial centre for family-wealth structures, and the absence of estate-tax treaties with Canada and the United States.