Succession: UAE → Kazakhstan

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.

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 workable route: choose the applicable law in the will in advance and/or move assets into a structure (foundation, trust, holding) where shares are inherited rather than the assets themselves.

Where tax arises

UAE: No inheritance tax.

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).

What to set up in advance

Will with a choice of applicable law

Trust

Private foundation

Insurance wrapper for assets

Part of the estate is reserved by UAE law for close relatives — it cannot be freely reallocated by will.