You can absolutely keep your home-country Will valid while living in the UAE. In fact, many expatriates maintain a foreign Will for overseas assets while using a UAE Will for local property and guardianship. There are two recognized methods to ensure your foreign Will remains legally effective:

A DIFC Will can include assets located outside the UAE, provided the foreign jurisdiction accepts a DIFC-issued probate order. Because the DIFC operates under a common-law framework, it aligns naturally with countries such as:

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• United Kingdom
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• United States
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• Singapore
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• India
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• Australia
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How it works:

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• You register a Will in the DIFC that includes foreign assets.
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• When you pass away, DIFC probate is initiated.
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• The DIFC Court issues an execution approval or probate order specific to the foreign jurisdiction.
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• That document is then used to commence local probate in the relevant country.
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This makes DIFC the most seamless option for individuals with cross-border estates.

Many embassies in the UAE allow expatriates to sign and attest a home-country Will before a consular officer.

Once attested, the Will is fully valid for use in the home country’s legal system.

Examples:

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• Indian nationals typically use IVS Global (outsourced by the Indian Embassy/Consulate) to notarize and register their Wills.
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• Other embassies offer similar attestation services depending on their national procedures.
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This option is ideal if you prefer to keep your Will strictly governed by your home country’s laws.

Both approaches ensure that UAE residents can secure their non-UAE assets while living abroad.

The choice depends on whether you want a UAE-based Will with international reach (DIFC) or to maintain a locally recognized Will in your home country (embassy attestation).

Either way, your foreign assets remain protected and legally transmissible according to your intentions.

The UAE allows a broad range of individuals to register a Will, provided they meet certain basic legal criteria. To register a Will, a person must be:

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• At least 21 years old,
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• Of sound mind, and
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• Acting voluntarily and without undue influence.
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Beyond these core requirements, eligibility depends on residency status and asset location.

Anyone holding a UAE residence visa—regardless of nationality or religion—may register a Will in any of the recognized jurisdictions:

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• ADJD (Abu Dhabi Judicial Department)
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• Dubai Courts
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• DIFC Wills Service Centre
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Residents commonly register Wills to cover local real estate, bank accounts, investments, business shares, and guardianship of minor children.

Non-residents who own assets in the UAE—such as property, bank accounts, or investments—may also register a Will.

DIFC is the most common choice for non-residents because:

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• The process is entirely online,
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• Wills are drafted and probated in English, and
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• One Will can cover assets in multiple countries.
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Historically, Muslim expats faced restrictions, but since mid-2021, ADJD and Dubai Courts allow Muslim expatriates to register Wills.

This is a significant development, as it enables Muslims to opt out of default Sharia inheritance rules.

Non-Muslims have always been able to register Wills across all jurisdictions.

Couples may register:

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• Mirror Wills (two separate Wills with reciprocal terms), or
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• A joint Will (allowed in DIFC).
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Parents can also appoint temporary and permanent guardians for children under 21—one of the most important reasons expatriate families register a Will in the UAE.

You can register a Will in the UAE if you:

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• Are 21+,
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• Have full mental capacity, and
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• Either reside in the UAE or hold assets in the UAE.
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The system is designed to give both residents and non-residents full control over how their assets and family arrangements are handled, ensuring clarity and protection in a jurisdiction where the default rules may not reflect one’s wishes.

Registering a Will in the UAE is a straightforward process, but several essential requirements must be met. The testator must be at least 21 years old, be of sound mind, and must act voluntarily, free from pressure or undue influence.

UAE Wills are typically drafted in broad, comprehensive terms to cover both existing assets and any future assets acquired after the Will is signed. This ensures that newly purchased property, bank accounts, or investments are automatically included without needing frequent amendments.

A typical Will contains three core components:

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• Executor Clause – appoints the individual(s) responsible for managing the estate.
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• Beneficiary Clause – specifies who will inherit the estate and in what proportions.
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• Guardianship Clause – names permanent and temporary guardians for children under 21.
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Backup or substitute appointments are normally included to ensure the Will remains valid even if an executor, guardian, or beneficiary passes away before the testator.

Once registered with ADJD, Dubai Courts, or DIFC, the Will becomes a private document, and court records are not publicly accessible.

DIFC Wills—while more expensive—offer key advantages:

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• entirely English-language drafting,
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• common-law procedures, and
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• a more streamlined and predictable probate process.
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When registering a Will in the UAE, individuals can choose from three primary jurisdictions—ADJD, Dubai Courts, and DIFC. Each offers different advantages in terms of cost, process, language, and flexibility.

Best for: Cost efficiency, full virtual process, expat Muslims

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• Cost: AED 950
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• Process: Fully virtual; no in-person visit required
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• Language: Bilingual Will (English–Arabic)
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• Probate: Conducted in Arabic
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• Practical note: If the family prefers not to manage the Arabic probate process, a Power of Attorney can be issued to a representative.
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• Special update: Since mid-2021, expat Muslims are allowed to register Wills at ADJD, making it the most popular option in this group.
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• Timing: Quick registration, though appointment availability can involve a 5–6 week wait due to high demand.
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Best for: Fastest appointment availability and walk-in registration

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• Cost: AED 2,150 per Will
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• Process: Very fast; usually completed within two days
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• Language: Bilingual Will (English–Arabic)
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• Probate: Conducted in Arabic
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• Key advantage: Same-week appointments are usually available, unlike ADJD, which may have delays.
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• Use case: Ideal for individuals needing quick registration or facing tight timelines.
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Best for: English-only Wills, international assets, and common-law structure

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• Cost:
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• AED 10,000 for a single Will
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• AED 15,000 for a mirror Will (couple)
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• (after the current 50% discount)
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• Process: Fully virtual; no in-person attendance needed
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• Language: Will and probate entirely in English
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• Legal system: Common-law framework
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• International capability: Allows inclusion of assets from multiple countries
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• DIFC can issue an “execution approval” enabling probate in jurisdictions such as India, Singapore, Australia, the UK, and the US.
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• Key advantage: Highest level of flexibility and simplicity for multinational families or globally diversified estates.
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When a person passes away in the UAE, the procedure that follows depends heavily on whether a valid Will is in place.

If a Will exists, the process is significantly simpler and more predictable.

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• The executor submits the Will, the death certificate, identification documents, and proof of assets to the court.
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• After the file is opened and reviewed, the court typically issues the probate order within six to eight weeks.
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• For Wills registered with the DIFC, the entire process can be handled virtually, and the executor may appoint a representative through a Power of Attorney.
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• Once the court order is issued, assets are transferred directly to the named beneficiaries.
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This route is the fastest, most orderly, and offers the highest degree of certainty for families.

If no Will exists, Sharia inheritance rules apply by default, which complicates and lengthens the process.

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• The family must identify all legal heirs under Sharia principles. Priority is given to parents, spouse, and children; in the absence of male heirs in this group, siblings are included.
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• All identification documents must be collected, and an appointment is scheduled with a judge.
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• Two witnesses must testify to confirm the list of heirs.
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• The court then issues a succession certificate, detailing each heir’s share.
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• The heirs must agree either to accept their portion or formally waive it in favor of another family member.
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• Only after this step can asset transfers begin.
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This process usually takes three to four months, and in some cases may extend to six months.

Individuals with UAE assets or residency may register a Will in any jurisdiction within the UAE, including:

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• DIFC
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• Abu Dhabi Courts (ADJD)
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• Dubai Courts
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• ADGM
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Without a Will, the court with authority is determined by either the deceased’s residence visa jurisdiction or the location of the assets.

In the UAE, having a legally registered Will is not optional — it is crucial. Without one, a person’s estate is automatically governed by Sharia inheritance rules, which impose predetermined shares for heirs regardless of the individual’s personal wishes.

When someone dies without a Will in the UAE, several complications follow:

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• Sharia rules apply by default, dictating how assets must be divided.
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• Guardianship of minor children is not automatically given to the surviving parent; the court appoints a guardian.
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• Asset transfers become slow and complex, requiring attestations, certified translations, and court approvals.
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• Bank accounts may remain frozen until the legal process is completed.
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A registered Will solves these issues by allowing you to:

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• Choose who inherits your assets.
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• Appoint guardians for minor children.
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• Specify executors and ensure the estate is managed according to your instructions.
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• Provide your family with a clear, efficient process during an already difficult time.
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A UAE Will is ultimately about control, protection, and peace of mind — ensuring your wishes are respected and your family is supported.

Custodial institutions and fiduciary structures may both “hold assets,” but legally they are completely different. The distinction comes down to the relationship, the level of discretion, and who is allowed to act on behalf of the owner. Under EU regulations, this difference determines why custodians remain allowed for Russians, while fiduciary services are banned.

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• Holds assets securely.
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• Cannot touch, manage, or move anything without explicit instruction.
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• Their duty is pure safekeeping.
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• Authorized to make decisions for your benefit.
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• Can buy, sell, and manage assets without constant permission.
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• Their duty is loyalty and prudent management.
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• Custodian: Principal–Agent or Bailor–Bailee. A contract for safekeeping and execution of instructions.
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• Fiduciary: Fiduciary–Beneficiary. A relationship of trust requiring good faith.
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• Custodian: Safekeeping and exact execution of instructions.
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• Fiduciary: Loyalty and prudence in managing assets.
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• Custodian: No discretion. Cannot make independent decisions.
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• Fiduciary: High discretion. Expected to make judgment calls.
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• Custodian: Holder of assets; operational, mechanical role.
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• Fiduciary: Manager of assets; judgment and strategy.
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• Custodian: Banks, brokerages, central securities depositories.
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• Fiduciary: Trusts (trustees), estates (executors), guardianships.
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• Custodian: Negligence — loss of assets or failure to follow instructions.
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• Fiduciary: Breach of fiduciary duty — conflicts, self-dealing, bad decisions.
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• Custodian: The client owns assets directly and gives instructions.
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• Fiduciary: The fiduciary controls assets; beneficiaries benefit but often do not control.
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Top Company (Custodial Institution)

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• The company’s articles and memorandum allow its shares to transfer automatically to designated third parties (typically family members) upon the shareholder’s death.
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• This mechanism does not create a trust, because there is no fiduciary relationship—only a custodial structure.
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• Therefore, it does not fall under EU trust-related sanctions, which target fiduciary and trust-like arrangements.
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• The company’s place of effective management (POEM) is in Svalbard, a CRS non-participating jurisdiction.
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• As a result, the top company is treated as a Non-Reporting Financial Institution (FI) for CRS purposes and has no CRS reporting obligations.
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• Its CRS classification is driven entirely by its activities and professional management, not by the tax residency of its shareholders.
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• Because the bottom company’s portfolio is professionally managed by a bank (a Financial Institution), it is classified as an:
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• Investment Entity (Professionally Managed)
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• This makes it a Financial Institution for CRS purposes, regardless of who owns it.
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• The bottom company has one equity holder: the top company (a non-reporting custodial FI located in Svalbard).
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Under CRS rules:

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• An equity interest held by a Financial Institution is not a “Financial Account”,
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• unless the entity is an Investment Entity in a non-participating jurisdiction.
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• Here, the shareholder is an FI in a non-participating jurisdiction, but not an Investment Entity.
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• Therefore, the holding is not a reportable account.
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3. The top company is a Non-Reporting FI located in a CRS non-participating jurisdiction (Svalbard).
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7. The bottom Investment Entity sees its owner as a Non-Reporting FI.
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11. Because of this, the bottom company:
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• Does not look through the top company,
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• Does not identify controlling persons,
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• Does not report the ultimate Russian shareholder under CRS.
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4. The Russian resident owner is not reported because the ownership is held through a recognized FI in a CRS-non-participating jurisdiction.
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8. No Exchange on Demand (EoD) applies because the Person with Significant Control (PSC) is resident in Svalbard — a territory with no tax information exchange agreements whatsoever due to treaty...