UAE
Succession:
Tax:
Geographic
Sharia default rules, DIFC Wills Service Centre, free zone asset treatment, non-Muslim will registration, homeCountryLawElection (Decree Law 41/2022), home country code + DIFC registration tracking
UAE succession law — dual-track (Sharia default vs DIFC common law), DWSC registered wills, expatriate handling under Federal Decree-Law No. 41/2022; includes ADGM wills service, non-Muslim court registration, UAE real property treatment, and dual-track dispute resolution (Sharia vs common law)
Maintained by
Testate Technologies Ltd
We're looking for a jurisdiction partner to co-maintain this extension — bringing local legal expertise while we handle the schema engineering. Get in touch →
Extension Fields
| Field | Type | Req | Description |
|---|---|---|---|
| adgmWill | object | Abu Dhabi Global Market (ADGM) Wills Service — alternative to DIFC for Abu Dhabi residents | |
| difcWill | object | DIFC Wills and Probate Registry details | |
| disputeResolution | object | Inheritance dispute resolution forum — dual-track system (Sharia vs common law) | |
| emirate | object | Which emirate the estate is primarily administered in — different emirates have different courts | |
| expatriateHandling | object | Under Federal Decree-Law No. 41/2022, non-Muslim expatriates may elect home country law | |
| freeZoneAssets | array | Assets held in UAE free zones may have different treatment | |
| homeCountryLawElection | object | Election to apply home-country succession law under Federal Decree Law No. 41 of 2022. Available to non-Muslims — allows election of home-country law instead of Sharia | |
| marriageRevocation | object | Whether and how marriage revokes a prior will. For UAE non-Muslim wills registered with DIFC or ADGM, marriage does not automatically revoke the will. Muslim estates are governed by Sharia fara'id regardless of marital status — will limited to 1/3 for non-heirs. | |
| nonMuslimWillRegistration | object | Non-Muslim will registration with local courts (Dubai Courts, Abu Dhabi Judicial Department) | |
| notes | string | ||
| propertyTreatment | object | UAE real property treatment — freehold only available to foreigners in designated areas | |
| shariaFixedShares | object | Sharia fixed-share (fara'id) application under UAE Personal Status Law (Federal Law No. 28/2005) | |
| successionTrack | object | Which succession track applies — Sharia (default for Muslims) or DIFC (opted-in for non-Muslims) |
Example Scenarios
2 case studies use this extension.
Al-Mizan Mediation Centre
Family mediation service using visibility controls to manage estate disclosure across cultures
Peninsula Heritage Advisors
Dubai-based wealth advisory firm handling high-net-worth expat estates spanning Gulf states and home countries
At a Glance
Get in touch
Have a question about UAE or want to contribute? We'd love to hear from you.
Subject: Jurisdiction Enquiry — UAE