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UAE succession law for non-Muslims can be deeply unfamiliar to UK families. Without a registered DIFC will, Sharia principles may govern UAE property regardless of a UK will's provisions. There is no UAE inheritance tax, but UK IHT applies.
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Dubai and Abu Dhabi have attracted a large community of UK expats and investors. Many UK citizens own UAE freehold property — particularly in designated investment areas in Dubai — as well as bank accounts and business interests. The UAE's Islamic law framework creates unique succession challenges for non-Muslim UK citizens that are markedly different from European or Commonwealth jurisdictions.
This guide explains how UAE succession law applies to non-Muslims, the critical importance of registering a DIFC will, the UAE administration process after death, the absence of UAE inheritance tax, and UK IHT.
The UAE Personal Status Law (Federal Law No. 28 of 2005) applies Sharia inheritance principles to the succession of Muslims. For non-Muslims, the law historically allowed non-Muslims to register their will with the UAE courts, but the default — in the absence of a valid registered will — was sometimes to apply Sharia principles.
Under Sharia inheritance rules, the distribution is very different from typical UK wills:
In 2022, the UAE introduced significant reforms allowing non-Muslims to choose the law of their home country to govern their succession in the UAE, but the practical implementation varies by emirate and requires correct documentation to be in place before death.
The Dubai International Financial Centre (DIFC) operates the DIFC Wills Service Centre, which allows non-Muslim expats and investors to register wills that are governed by English law (common law) and exclude Sharia inheritance rules from applying to UAE assets.
Key features of the DIFC Wills Service:
DIFC wills are recognised across all UAE courts and provide the clearest and most reliable protection for non-Muslim UK citizens with UAE assets. The registration fee is typically a few thousand UAE dirhams depending on the type of will.
Without a registered DIFC will, a UK will alone may not be recognised as effective in the UAE, particularly for real property.
When a UK citizen dies holding UAE assets, the process depends on whether a DIFC will was registered:
For authenticating UK documents for use in UAE proceedings, see our guide on obtaining an apostille for a foreign death certificate. Note that the UAE is not a signatory to the Hague Apostille Convention — UAE documents require consular legalisation rather than an apostille for use outside the UAE; foreign documents used in the UAE require legalisation through the UAE consulate and the relevant UAE ministry.
There is no inheritance tax, estate duty, or capital gains tax in the UAE. Beneficiaries receiving UAE assets pay no UAE tax on the inheritance itself. This is a significant advantage compared to European jurisdictions.
UAE bank accounts are subject to the bank's own procedures on death. Banks typically freeze accounts on notification of death and require court orders or the DIFC grant before releasing funds. This can cause immediate practical difficulties if the family has no access to cash. The executor should act quickly to deal with UAE bank accounts.
A UK-domiciled person's UAE property is part of the worldwide estate subject to UK IHT. UAE property must be valued at market value at the date of death and declared on the IHT400 with the IHT417 foreign assets schedule.
There is no UK–UAE double taxation treaty covering inheritance taxes. No credit is available for UAE taxes on inheritance (because there are none). See our UK IHT guide for current thresholds.
Other Middle Eastern countries present similar or greater challenges for UK citizens with assets there:
For any Middle Eastern estate, early specialist local legal advice is essential before any assets are dealt with.
For the UK side of the administration, see our estate administration checklist, complete UK probate guide, and our UK inheritance tax guide. For documents needed, see what documents you need for probate. For cross-border estate planning, see our guide on multiple wills in different jurisdictions. For apostilling documents, see our guide on apostilling a foreign death certificate.
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