How does inheritance work for non-Muslim expats in the UAE?

Non-Muslim expats in UAE can register wills at DIFC or Abu Dhabi registries to control estate distribution. Without registration, courts may apply S

Under the Civil Personal Status framework, a non-Muslim foreign resident has options for how their estate is distributed ^[1]:

Default: assets located in the UAE are distributed under the civil framework or the law of the deceased's nationality, depending on the choice the deceased made (and registered) during their lifetime.
DIFC Wills Service Centre: any non-Muslim (resident or not) can register a will at the DIFC Wills service that governs UAE-located assets. This is widely used and gives strong certainty.
Abu Dhabi Judicial Department non-Muslim wills registry: equivalent registration option for Abu Dhabi.
Home-country will: can be used but typically requires UAE-court recognition, which is slower than registering locally.

Why registering matters:

Without a registered will, UAE courts may default to Sharia distribution rules, which can produce results most non-Muslim families do not expect (e.g., children's shares determined by gender, surviving spouse not being the primary heir).
A registered will lets you appoint executors, guardians for minor children, and specify exact percentages.

The will must comply with formal requirements (witnessed, signed, notarised through the relevant registry).

For advice on cross-border estates, business shares, or trusts, consult a UAE-licensed estate-planning lawyer.

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