Millions of people relocate to the UAE, Europe, or Southeast Asia every year. Many of them have a will. Almost none of them have a will that actually works where they now live, and where their assets are now held.
An international will is not a single document with global effect. It is a succession strategy that accounts for the laws, jurisdictions, and court systems that will govern your estate when you die.
This guide is part of our broader estate planning framework for internationally mobile HNWIs.
For expats living in the UAE, effective succession planning means understanding the interaction between UAE federal succession law, DIFC common law frameworks, and the laws of your country of origin. Each layer can apply to different parts of your estate, often simultaneously.
An international will is a will specifically designed to be recognised and enforceable across more than one jurisdiction, addressing the succession of assets held in different countries under different legal systems.
An international will is not a single universally recognised document. The Washington Convention on International Wills (1973) established a standard form for wills intended for use across multiple countries. A number of countries (including the UK, US, Canada, France, and Italy) are signatories. However, many countries are not party to the Convention, and compliance with its formalities does not guarantee that the will is recognised everywhere.
The most common misconception among expats is that a will drafted in their home country will cover their assets wherever they are located. In most cases, this is incorrect. Four reasons a domestic will fails across borders:
| Framework | Scope | Key provision |
|---|---|---|
| Washington Convention (1973) | Signatory countries (UK, US, France, etc.) | Establishes standard form will recognised across signatories |
| EU Succession Regulation / Brussels IV (2015) | EU member states | Allows EU nationals to elect nationality law for worldwide estate |
| Hague Convention on Succession (1989) | Limited adoption | Provides conflict-of-laws rules for international estates |
| UAE federal law | UAE residents | Applies Sharia succession by default; allows home country law for non-Muslims in some cases |
| DIFC Will (registered) | Non-Muslim individuals with UAE assets | Civil law succession for covered assets, overriding UAE federal default |
None of these frameworks provides a single document with worldwide effect. The practical solution for most internationally mobile HNWIs is a coordinated multi-will strategy: a will in the country of domicile covering the worldwide estate (with carve-outs for UAE assets), and a DIFC-registered will covering UAE assets specifically.
For expats living in the UAE, succession planning must account for two legal environments simultaneously: the laws of the home country (which may still apply to non-UAE assets and to the individual's domicile status) and UAE law (which applies to assets located in the UAE).
The default position for a deceased non-Muslim expat is complex. The UAE courts may apply the law of the deceased's nationality to their estate, but this requires the courts to apply foreign law, which is not always straightforward, is subject to public policy exceptions, and can result in significant delays. Without a registered will, the process for non-Muslims can be uncertain and lengthy.
A will registered with the DIFC Wills Service Centre provides a clear, enforceable instruction for the distribution of covered assets under civil law principles, without requiring the UAE courts to apply foreign succession law. This is the most practical route for non-Muslim expats with UAE assets.
If a non-Muslim expatriate dies in the UAE without a registered DIFC will, UAE courts may freeze their bank accounts and other UAE assets until the estate is determined - a process that can take months or years and may produce outcomes the deceased did not intend.
Every wealth journey starts with a conversation. Our advisers are ready to understand your objectives, assess your circumstances, and build a strategy tailored to your goals.
Begin Your Journey With UsThe DIFC Wills Service Centre (DIFC WSC) is a registration facility established specifically for non-Muslim individuals who hold assets in the UAE. It operates under the DIFC common law framework, independently of UAE federal succession law.
The UAE applies Islamic succession principles to the estates of Muslims. For non-Muslims, the default position under UAE federal law is less certain, but Sharia-derived rules can apply in some circumstances, particularly for real estate assets.
For non-Muslim expats, the key points:
The DIFC Wills Service Centre introduced an expanded will format in 2022 that covers all UAE-situated assets (not just DIFC-located assets), extending protection to real estate and bank accounts across all seven Emirates.
For most expatriates with assets in both their home country and the UAE, the most practical succession strategy involves two coordinated wills.
Will 1 - Home country will: Covers worldwide assets, or all assets except UAE-situated assets. Drafted in the home country, in accordance with local formalities, and subject to the home country's succession law. If the home country is a signatory to the Washington Convention, the standard form may provide additional enforceability.
Will 2 - DIFC-registered will: Covers UAE-situated assets specifically (moveable and immoveable). Registered with the DIFC Wills Service Centre. Provides civil law distribution outcomes for UAE assets, overriding the default application of UAE federal succession rules.
Coordination is essential: The two wills must be drafted together, or reviewed together, to ensure that they do not contradict each other, do not leave any assets uncovered, and do not both claim to cover assets that the other also addresses. A conflict between two wills can result in probate proceedings in both jurisdictions simultaneously.
For HNWIs with assets in additional jurisdictions, complementary structuring through holding companies and trusts can reduce the number of jurisdictions where a will is required by consolidating asset ownership at the entity level.
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An international will is a succession document designed to be recognised and enforceable across more than one jurisdiction. As an expat with assets in the UAE and your home country, a domestic will alone is insufficient. You need a succession strategy that covers assets in each jurisdiction where you hold them, typically through a combination of a home country will and a DIFC-registered will for UAE assets.
The DIFC Wills Service Centre allows non-Muslim individuals to register a will that governs the succession of their UAE-situated assets under civil law principles, overriding the default application of UAE federal succession rules. This provides certainty of outcome for UAE-based assets, avoids potential application of Sharia succession proportions, and makes the administration of the UAE estate significantly more straightforward. Begin Your Journey With Us to discuss how to register a DIFC will.
By default, UAE courts may apply UAE succession law (influenced by Sharia) to assets located in the UAE, including the property of non-Muslims. For non-Muslims who register a will with the DIFC Wills Service Centre, the registered will takes precedence for covered assets, providing civil law succession outcomes and removing the risk of Sharia proportions being applied by the UAE courts.
Yes. A dual-will strategy is the standard approach for internationally mobile expats. A home country will covers worldwide assets (or all assets except UAE-situated assets), and a DIFC-registered will covers UAE assets specifically. The two wills must be drafted or reviewed together to ensure they do not contradict each other and that all assets are covered. Contact us for more information about coordinating a multi-will succession strategy.
Without a registered will, your UAE assets will be subject to UAE federal succession law, which may apply Islamic succession principles regardless of your religion, freeze your bank accounts and other assets pending court determination, and result in a distribution that does not reflect your wishes. The process can take months or years and may produce outcomes that could have been avoided with a registered DIFC will.
