Peninsula Heritage Advisors

The Problem#

• Dubai attracts high-net-worth expatriates who hold assets across three or more jurisdictions: property in Dubai, investments in the UK, ancestral property in India
• The default succession law in the UAE is Sharia — which applies automatically to Muslim residents and was historically applied to all residents; non-Muslim expats can opt out via a DIFC will or under Federal Decree-Law No. 41/2022, but 60% of non-Muslim expats have not done so
• Each jurisdiction has different forced heirship rules, tax obligations, and procedural requirements
• A Hindu client with ancestral property in India faces Hindu Succession Act coparcenary rules that cannot be overridden by will — even from Dubai
• A three-jurisdiction estate without structured data sharing typically incurs $150,000–$250,000 in advisory fees and takes 18–24 months

How They’d Use INHERIT#

• Peninsula Heritage uses three extensions simultaneously: uae, india, and uk-england-wales
• The uae extension’s successionTrack records whether the estate follows "sharia", "difc", or "decree_law_41_home_country" rules; for DIFC wills, the difcWill object captures registration details and willType
• For Hindu clients, the hindu-succession extension’s HUFDetails captures the Hindu Undivided Family structure — kartaPersonId, Coparcener[] entries with coparcenaryShareFraction; the india extension’s personalLaw confirms the succession regime
• UK assets use the uk-england-wales extension with nilRateBand and residenceNilRateBand calculations
• common/tax-position.json captures double taxation treaty positions between all three jurisdictions
• property.json entries for each jurisdiction include common/jurisdiction.json references indicating which country’s law governs that specific property

The Integration#

• Bidirectional: Peninsula Heritage creates and maintains INHERIT documents for each client, sharing relevant sections with local advisers in each jurisdiction
• The Dubai-based lead adviser consolidates inputs from the Indian lawyer (coparcenary details), the UK solicitor (IHT calculations), and the DIFC registry (will registration)
• A single authoritative document replaces the current patchwork of jurisdiction-specific files

The Business Case#

• INHERIT-structured data sharing reduces advisory fees by 30% — from $150,000–$250,000 to $100,000–$175,000 per estate
• Total administration time reduces by 40% — from 18–24 months to 10–14 months
• Across 40–50 multi-jurisdiction estates per year, total client savings are approximately $3 million annually
• Critical risk mitigation: identifying Sharia default application to non-Muslim expats who have not registered a DIFC will — preventing complete loss of testamentary freedom

Before / After#

Without INHERIT:

1. High-net-worth expat dies in Dubai with property in the UAE, investments in the UK, and ancestral land in India
2. Three separate legal teams are engaged — each works in isolation with no visibility of the others’ progress
3. The Dubai team discovers no DIFC will was registered; Sharia applies by default, overriding the deceased’s intended distribution
4. The Indian lawyer discovers coparcenary property that cannot be willed — contradicting the UK solicitor’s assumptions
5. Coordination takes 18–24 months; advisory fees reach $250,000; the family receives a distribution nobody intended

With INHERIT:

1. Peninsula Heritage maintains a single INHERIT document covering all three jurisdictions
2. The uae extension flags Sharia default risk; the hindu-succession extension models coparcenary restrictions; the uk-england-wales extension calculates IHT
3. Conflicts are identified during the client’s lifetime — a DIFC will is registered, coparcenary property is restructured
4. Expat dies; the succession plan executes across all three jurisdictions in 10–14 months with advisory fees of $100,000–$175,000