More than 50,000 Americans call the United Arab Emirates home — drawn by tax-free salaries, world-class infrastructure, and the cosmopolitan energy of Dubai and Abu Dhabi. But beneath the gleaming skyline lies a legal reality that catches many expats off guard: without a properly registered will, your UAE assets could be distributed under Sharia inheritance principles, regardless of your religion or nationality.
This guide explains everything an American living in the UAE needs to know about writing a valid will, protecting a spouse and children, navigating dual-country estate tax obligations, and using the DIFC Wills Service Centre to safeguard your estate.
The UAE is a federation of seven emirates governed primarily by federal law, but personal status matters — including inheritance — have historically been handled under Islamic (Sharia) law for everyone, including non-Muslims. This changed significantly with the introduction of the DIFC Wills Service Centre in 2015 and subsequent reforms, but the risk of Sharia default remains very real if you die without a registered will.
Under Sharia inheritance rules, a wife typically inherits one-eighth of her husband's estate (if children are present), and daughters receive half the share of sons. Non-Muslim beneficiaries may face complications in claiming assets. This is starkly different from what most Americans expect when they think about leaving everything to a spouse or splitting assets equally between children.
In 2023, the UAE amended its Civil Transactions Law to allow non-Muslim foreigners to elect that their home country's law governs their estate. This is a meaningful reform — but only if you take action to assert it. A registered will is the best way to invoke this right and ensure it is honored by UAE courts without expensive, time-consuming litigation by your heirs.
The Dubai International Financial Centre (DIFC) Wills Service Centre is the most established mechanism for non-Muslim expatriates to register a will governing their UAE assets. A DIFC Will:
The DIFC Wills Service Centre offers five will types: Full Estate Will, Property Will, Financial Assets Will, Company Ownership Will, and Guardianship Will. Most Americans with significant UAE assets should consider a Full Estate Will or a combination of Property and Financial Assets wills.
If you hold significant assets in Abu Dhabi, the Abu Dhabi Judicial Department (ADJD) offers a parallel non-Muslim will registration service. An ADJD will covers assets located in Abu Dhabi Emirate. If you have assets in both Dubai and Abu Dhabi, you may need both a DIFC Will and an ADJD Will — or a carefully drafted full-estate will that covers both jurisdictions.
ExpatLegalWills helps Americans abroad create a legally valid will governed by US state law — the foundation of your cross-border estate plan. Start online in minutes.
Start Your Expat Will at ExpatLegalWills →One of the most important — and most overlooked — issues for Americans abroad is that the United States taxes its citizens on their worldwide estate. This does not change because you live in Dubai or Abu Dhabi. When you die, the IRS will require your estate to file Form 706 (United States Estate Tax Return) if the gross value of your worldwide estate exceeds the federal exemption threshold.
For 2026, the federal estate tax exemption is approximately $13.99 million per individual (adjusted for inflation from the Tax Cuts and Jobs Act amount). Married couples can effectively double this through portability. Estates exceeding this threshold are taxed at up to 40%.
Important note: Unless Congress acts, the TCJA's doubled exemption is scheduled to sunset after December 31, 2025, reverting to approximately $7 million per individual (inflation-adjusted). The political situation is fluid; keep watch on this issue and consult a US estate planning attorney.
The good news: the UAE levies no inheritance or estate tax on UAE-held assets. There is no US-UAE estate tax treaty, but since the UAE side has zero tax, the practical effect is that you only face US-side estate taxes. Your heirs won't pay tax in both countries.
If you were married in a US community property state (California, Texas, Arizona, etc.) before moving to the UAE, community property principles may still affect how your worldwide estate is characterized for US tax purposes. A qualified US estate attorney can advise whether a Community Property Agreement or other planning tool is appropriate.
For a will registered through the DIFC Wills Service Centre to be valid, you must:
The registration process typically takes one to two weeks from start to finish, including an online pre-registration form, document preparation, and an in-person registration appointment. The will must be written in English (Arabic translation is made available by the DIFC registry).
A US will may be recognized in the UAE, but enforcement is uncertain and time-consuming. UAE courts are not automatically bound to apply a foreign will, and the probate process for a foreign will can take years. The practical advice from estate attorneys is consistent: register a DIFC or ADJD will to cover UAE assets in addition to your US will, rather than relying on a single document.
If you have minor children living in the UAE with you, naming a guardian in your UAE will is critical. Under UAE federal law, custody disputes involving foreign children can be complex, and a registered guardianship will through the DIFC significantly strengthens your appointed guardian's legal standing. Without such a document, UAE authorities may not automatically recognize the guardian named in your US will.
The DIFC Guardianship Will covers children who are UAE residents at the time of the testator's death and names both a primary and alternate guardian. It is strongly recommended for any American parent living in the UAE.
If you own property in Dubai or Abu Dhabi (many Americans hold freehold property in designated areas), this asset is subject to UAE jurisdiction on death. A Property Will registered through the DIFC or ADJD is the cleanest way to ensure it passes as you intend. Without one, the Dubai Land Department may freeze the property pending a court order, causing significant delays for your heirs.
UAE-based bank accounts are local assets subject to UAE law. A Financial Assets Will registered through the DIFC covers accounts and investments held in Dubai. ADJD wills cover Abu Dhabi-based accounts. You should keep a record of all UAE financial accounts and their institutions for your executor.
If you are employed in the UAE, you have likely accrued an end-of-service gratuity — a statutory payment made to employees upon termination or death. This is distinct from your regular estate and is typically paid directly by your employer to your next of kin. The distribution of EOSB is governed by UAE labor law, not your will. However, naming your employer's HR department in your estate plan documents and ensuring your next-of-kin information is current can avoid unnecessary delays.
Americans in the UAE need both a US-law will and UAE-registered documents. ExpatLegalWills specializes in exactly this situation — creating a will that works alongside your UAE registrations.
Create Your Expat Will Now →ExpatLegalWills is an online platform built specifically for expatriates. For Americans in the UAE, it helps you create a legally valid will governed by your chosen US state law — the foundation of your international estate plan. The platform walks you through appointing executors, naming beneficiaries, providing for children, and even leaving specific bequests or charitable gifts.
While ExpatLegalWills creates the US-law layer of your estate plan, you would then take that document to the DIFC or ADJD alongside your UAE-specific will registrations. The combination ensures comprehensive coverage: your US-based and worldwide moveable assets are governed by the US will, while your UAE real estate and financial accounts are covered by the registered UAE wills.