01Applicable 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.
Succession: UAE → Portugal
What happens to the estate
Case complexity: medium. The testator resides in UAE, the heir resides in Portugal.
Testator
Citizen of UAE
Resident of UAE — the centre of life.
Heir
Resident of Portugal
The estate stays in one jurisdiction — a simpler process.
0%
inheritance tax in UAE — but assets are taxed where they sit.
02Forced 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 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.
03Tax
Where tax arises
- UAE: No inheritance tax.
04Recognition
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).
05What to set up
What to set up in advance
Key risk
Part of the estate is reserved by UAE law for close relatives — it cannot be freely reallocated by will.
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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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