United Arab Emirates.

The United Arab Emirates operates a dual-track succession system unique among Gulf jurisdictions. For Muslim decedents, Sharia faraid applies under federal personal-status law, with compulsory shares limiting testamentary disposition to one-third of the estate. For non-Muslim residents, Federal Decree-Law 41/2022 (in force 1 February 2023) introduced a comprehensive civil personal-status framework, expressly permitting non-Muslims to opt for testamentary freedom under foreign or civil law principles.

The UAE’s distinctive innovations are the DIFC Wills Service Centre (since 2015) and ADGM Wills regime (since 2017) — common-law Wills registries enabling non-Muslim expatriates to create internationally recognized wills enforceable through the DIFC and ADGM courts respectively. Both common-law enclaves operate under English-derived legal systems with their own probate procedures, separate from the federal Sharia courts. The UAE imposes no federal inheritance, estate, or gift tax.

The memoranda in this series address the recurring fact patterns in UAE cross-border estate planning — including the choice between DIFC/ADGM common-law Wills and federal civil personal-status proceedings, Federal Decree-Law 41/2022 mechanics for non-Muslim residents, real-property succession and the freehold-zone framework, the status of family businesses across mainland and free-zone jurisdictions, and the absence of estate-tax treaties with Canada and the United States.