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Succession Navigator

Succession: UAE → China (mainland)

What happens to the estate

Case complexity: medium. The testator resides in UAE, the heir resides in China (mainland).

Testator

Citizen of UAE

Resident of UAE — the centre of life.

Heir

Resident of China (mainland)

The estate stays in one jurisdiction — a simpler process.

0%

inheritance tax in UAE — but assets are taxed where they sit.

Applicable law

Which law decides who gets what

  • Under UAE rules, money, accounts and shares are inherited by the law of the country where the person lived, while real estate follows the law of the country where it physically sits.

Forced heirship

Who the law forces you to include

  • UAE: For Muslims — Sharia shares. For non-Muslims, since Federal Decree-Law No. 41/2022 (in force 2023) Sharia no longer applies by default: UAE civil rules apply, or the law of the home country by election; for certainty — a DIFC/ADGM will.
  • A choice of law in the will or a transfer into a structure needs separate review: neither guarantees removal of reserved shares, recovery claims or taxes.

Tax

Where tax arises

  • UAE: No inheritance tax.

Recognition

How it is recognised and processed

  • Testator and heir in different countries — documents will need cross-jurisdiction recognition and legalisation (apostille, translation, sometimes a repeat procedure).

FAQ

Which law governs the estate when the testator lives in UAE and the heir lives in China (mainland)?
Under UAE rules, money, accounts and shares are inherited by the law of the country where the person lived, while real estate follows the law of the country where it physically sits.
Is there forced heirship?
UAE: For Muslims — Sharia shares. For non-Muslims, since Federal Decree-Law No. 41/2022 (in force 2023) Sharia no longer applies by default: UAE civil rules apply, or the law of the home country by election; for certainty — a DIFC/ADGM will. A choice of law in the will or a transfer into a structure needs separate review: neither guarantees removal of reserved shares, recovery claims or taxes.
What inheritance taxes apply?
UAE: No inheritance tax.
How is the estate administered between UAE and China (mainland)?
Testator and heir in different countries — documents will need cross-jurisdiction recognition and legalisation (apostille, translation, sometimes a repeat procedure).

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This is general guidance, not legal advice. The rules are simplified; confirm current rates and details with a lawyer.

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