UAE Wills for UK Expats: DIFC Wills, Sharia Law and What You Need

UAE Wills for UK Expats: DIFC Wills, Sharia Law and What You Need

Important: This article covers general information about UAE will registration. Wills and inheritance law is complex and jurisdiction-specific. Speak to a qualified legal professional before making decisions about estate planning in the UAE.

If you live in the UAE and own assets here, you should have a UAE will. A UK will does not automatically cover UAE assets. Without a UAE will, local courts may distribute your estate under Sharia succession principles.

This catches many UK expats off guard. They assume their UK will, or their family setup, will handle everything. In the UAE, that assumption can leave your family with real problems.

What happens to your UAE assets if you die without a will?

If you do not have a registered will in the UAE, the local courts deal with your estate.

The UAE is a civil law country with Sharia-based inheritance rules for Muslims. For non-Muslims, the UAE courts can apply the law of the deceased’s home country if certain conditions are met. But that does not happen automatically. It needs legal proceedings. It takes time. It costs money.

During that process, bank accounts may be frozen. Property may be locked. Your spouse and children cannot access assets while the estate is being settled.

If Sharia succession principles apply, the distribution may not match what you intended. Sharia rules give set shares to set family members. A spouse does not automatically inherit everything.

The worst cases usually involve couples where one partner dies and the surviving spouse cannot access the joint account or the jointly owned property for months while the legal process runs.

A registered UAE will helps avoid that. It gives the courts clear instructions and usually speeds things up.

Sharia law default succession: who inherits what in the UAE?

For context, a standard Sharia inheritance split looks like this.

A widow usually receives one-eighth of the estate if there are children, or one-quarter if there are no children. The remaining assets go to children and male relatives under fixed fractions.

This is different from UK assumptions. In the UK, a spouse often inherits everything and children receive the rest. In the UAE, that outcome is not guaranteed without a will.

For non-Muslims, courts can apply the law of the deceased’s nationality. But you need documents and legal help to prove it. The process is not quick, and it is not cheap.

A registered will removes a lot of that uncertainty. It tells the court exactly what you want and how you want your assets divided. The court follows the will instead of working out which law applies.

Are UK wills valid in the UAE?

A UK will is not directly enforceable in the UAE. UAE courts do not accept it on its own unless it goes through a recognition process.

That process is often called will recognition or will attestation. It means getting the UK will certified, translated, and then submitted to UAE authorities for recognition.

The process can work, but it takes time and money. It is also not guaranteed. The UAE court still has discretion.

The simpler option is to have a separate UAE will for UAE assets. The will is drafted, signed, and registered in the UAE. It covers UAE-based assets only. Your UK will continues to cover your UK assets.

Many UK nationals who own property or significant assets in the UAE use two wills, one in each country. Each one covers the assets in that jurisdiction.

If you own UAE property, read the guide on buying property in the UAE as a UK resident for more context on ownership structures that affect inheritance.

How to register a will through the DIFC Will and Probate Registry

The DIFC, or Dubai International Financial Centre, has a dedicated will service for non-Muslim expats. The DIFC Wills Service Centre is the main registration route for UK nationals in Dubai.

What the DIFC will cover:

  • UAE assets generally: property, bank accounts, investments, company shares, personal effects
  • Guardianship of minor children

What it does not cover:

  • Assets outside the UAE. Your UK assets are covered by your UK will.
  • Business succession in free zones that run their own rules.

The registration process:

Step 1: Draft the will with a DIFC-approved will draftsman or with your own legal adviser who knows DIFC requirements.

Step 2: Book an appointment at the DIFC Wills Service Centre. You attend in person.

Step 3: The will is registered in the DIFC courts system. You receive a registration certificate.

The process usually takes a few hours on the day of registration. Drafting takes longer, depending on how complex your estate is.

Cost: Registration fees are around USD 1,500 to USD 2,000, depending on the type of will, such as a Dubai will, UAE will, or guardianship will. Drafting fees are separate and depend on your legal adviser.

Abu Dhabi option: The Abu Dhabi Judicial Department runs a similar service for Abu Dhabi-registered assets. If you have property or significant assets in Abu Dhabi, you may need a separate Abu Dhabi will alongside a Dubai will.

Do UK citizens pay inheritance tax as expats in Dubai?

There is no inheritance tax in the UAE. The UAE does not charge inheritance or estate tax on assets held there.

UK inheritance tax is more complicated.

HMRC charges inheritance tax on the worldwide estate of UK-domiciled individuals. Domicile is different from residency. You can live in the UAE for 10 years and still be UK-domiciled if the UAE is not your permanent home.

If you are UK-domiciled, your UAE assets count towards your estate for UK inheritance tax purposes. The nil-rate band, currently £325,000 and subject to change, applies first. Assets above that threshold are taxed at 40%.

Changing UK domicile is difficult. You need to show a settled intention to live permanently in the UAE. Many UK expats keep their UK domicile throughout their working life, even if they live abroad for years.

If UK inheritance tax applies to your estate, the UAE will still help distribute UAE assets quickly. The UK tax calculation still happens separately.

Get advice from a cross-border estate planning specialist if your estate is complex or large. This is not a DIY area.

UAE will vs UK will: which covers what?

UK will UAE will
UK property Yes No
UK bank accounts Yes No
UK company shares Yes No
UAE property No Yes
UAE bank accounts No Yes
UAE company shares No Yes
Guardianship of children Yes Recommended also in UAE

Keep both wills up to date when your circumstances change. Review them every 3 to 5 years, or after major life events such as buying property, having children, divorce, or a significant financial change.

What about children and guardianship?

For UK families with children living in the UAE, a guardianship designation matters a lot.

If both parents die without a UAE will naming a guardian, the courts handle it. UAE courts may not automatically appoint the guardian you would have chosen. In some cases, the child’s country of origin is contacted to find relatives.

The DIFC Wills Service Centre lets you register a guardianship will that names who should care for your children if both parents die. This is separate from the asset will, but it is just as important.

If long-term UAE residency for UK professionals is your plan, a guardianship will should be one of the first documents you put in place when you have children.

How We Help

If you are building a long-term life in the UAE and want to see how long-term UAE residency planning fits with your estate planning, the team can connect you with the right specialists.

Frequently Asked Questions

Are UK wills valid in the UAE?

A UK will is not directly enforceable in UAE courts. It can be recognised through a legal process, but that takes time and is not guaranteed. Most UK expats with UAE assets register a separate UAE will through the DIFC Wills Service Centre to cover UAE-based assets.

How much does it cost to make a will in Dubai for expats?

DIFC will registration fees are around USD 1,500 to USD 2,000. Drafting fees with a legal adviser are separate and depend on how complex your estate is. A standard dual-will package for Dubai property and bank accounts typically costs USD 3,000 to USD 5,000 all in.

Do expats need a will in the UAE?

Yes, if they own UAE assets or have children living in the UAE. Without a UAE will, UAE courts may apply Sharia succession principles or require long legal proceedings to work out which law applies. That can freeze assets and create serious delays for your family.

What happens to assets in the UAE without a will?

UAE courts may apply Sharia succession principles, which give specific shares to family members. Bank accounts can be frozen and property cannot be accessed until the estate is settled. The process can take months and can lead to significant legal costs.

Table of Contents