Why British Expats in Dubai Need Two Wills and One Clear Plan
Lamera Capital
2025-10-27
For many British professionals, Dubai is where global ambitions take shape. Yet amid property portfolios and cross-border investments, one issue is often overlooked; how those assets are handled when the time comes.
A UK will does not automatically apply in the UAE. Without the right legal planning, Dubai-based assets may be distributed under Sharia succession rules, even if that’s not your intention.
In 2025, the message from estate planners is clear: British expats need two coordinated wills, one for the UK and one for Dubai, to ensure that their wishes are respected across both legal systems.
Understanding the Divide: Two Systems, One Estate
The UK and UAE operate under entirely different inheritance laws.
In the UK, common law and testamentary freedom allow you to leave assets to whomever you choose.
In Dubai, unless you have registered a valid non-Muslim will, assets can fall under Sharia law, which allocates shares to family members according to prescribed formulas.
The UK and UAE operate under entirely different inheritance laws.
In the UK, common law and testamentary freedom allow you to leave assets to whomever you choose.
In Dubai, unless you have registered a valid non-Muslim will, assets can fall under Sharia law, which allocates shares to family members according to prescribed formulas.
Even with a perfectly valid UK will, your Dubai property or bank accounts could be frozen and distributed in ways you never intended.
The solution is to create a UAE-compliant will through the DIFC Wills and Probate Registry, which allows non-Muslims to register English-language wills covering Dubai and, since 2020, worldwide assets.
The solution is to create a UAE-compliant will through the DIFC Wills and Probate Registry, which allows non-Muslims to register English-language wills covering Dubai and, since 2020, worldwide assets.
Why It Matters: Certainty, Simplicity, and Control
A Dubai-registered will provides three key advantages:
- Legal certainty: It ensures Dubai assets follow your wishes, not automatic Sharia succession.
- Faster probate: Executors can obtain probate directly through the DIFC courts without navigating local court delays.
- Family protection: Guardianship provisions for minor children can be recognised in Dubai, avoiding unnecessary legal disputes.
For high-net-worth individuals, coordinated estate planning across jurisdictions can also reduce duplication, taxes, and future costs.
The Process: How to Register a Will in Dubai
The DIFC Wills Service is straightforward but must be precise.
You must be a non-Muslim, over 21 years old, and the legal owner of Dubai-based assets.
There are two main routes:
- Online registration: For financial or property wills, completed via video call.
- In-person registration: For full wills or guardianship wills, signed before a DIFC registrar.
Once executed, the will is stored with the DIFC and takes effect immediately upon your passing, giving your executors direct authority under Dubai law.
The UK Connection: One Plan, Two Jurisdictions
A Dubai will only applies within the UAE. To protect assets in the UK such as property, savings, pensions, or shares, a separate UK will is essential.
These wills must be drafted carefully to avoid revoking each other. Each document should clearly state its jurisdictional scope and be harmonised to prevent overlap or conflict. Poorly drafted wills can lead to delays, higher costs, and family disputes. Proper cross-border planning prevents all of these issues.
Professional Coordination Is Key
Leading firms with dual-qualified solicitors in both jurisdictions ensure the two wills work together seamlessly. Look for practitioners who are UK-qualified and registered with the Solicitors Regulation Authority, approved “Wills Draftsmen” by the DIFC, and STEP-accredited (Society of Trust & Estate Practitioners).
This dual expertise ensures your UK and Dubai wills align perfectly, protecting your estate from legal uncertainty and unnecessary expense.
The Financial Side Few Talk About
Property purchases, inheritance transfers, and tax payments all depend on timing and currency. Exchange rates move daily, and bank delays can quietly erode thousands in value.
That is where Lamera Capital comes in. We don’t just handle currency transfers; we strategically manage them using forward contracts and tactical timing to maximise return and preserve value.
The UK Connection: One Plan, Two Jurisdictions
A Dubai will only applies within the UAE. To protect assets in the UK such as property, savings, pensions, or shares, a separate UK will is essential.
These wills must be drafted carefully to avoid revoking each other. Each document should clearly state its jurisdictional scope and be harmonised to prevent overlap or conflict. Poorly drafted wills can lead to delays, higher costs, and family disputes. Proper cross-border planning prevents all of these issues.
Professional Coordination Is Key
Leading firms with dual-qualified solicitors in both jurisdictions ensure the two wills work together seamlessly. Look for practitioners who are UK-qualified and registered with the Solicitors Regulation Authority, approved “Wills Draftsmen” by the DIFC, and STEP-accredited (Society of Trust & Estate Practitioners).
This dual expertise ensures your UK and Dubai wills align perfectly, protecting your estate from legal uncertainty and unnecessary expense.
The Financial Side Few Talk About
Property purchases, inheritance transfers, and tax payments all depend on timing and currency. Exchange rates move daily, and bank delays can quietly erode thousands in value.
That is where Lamera Capital comes in. We don’t just handle currency transfers; we strategically manage them using forward contracts and tactical timing to maximise return and preserve value.
- Smarter execution: We track market movements and help you convert when conditions are in your favour.
- Faster settlement: Funds move same-day or next-day between the UK and UAE, avoiding costly delays.
- Better rates: Institutional-level pricing often saves clients two to three percent compared with standard bank rates.
- Forward planning: Lock in favourable rates before key legal milestones such as completion, probate distributions, or tax due dates.
- Precision documentation: Every conversion includes a clear trade ticket and settlement confirmation that your legal team can rely on.
Cross-Border Probate: Protecting Estate Value
For executors and beneficiaries managing estates split between the UK and UAE, timing conversions can make a substantial difference. Our approach to cross-border probate and property transactions applies the same principles whether working with UK-UAE estates or other international scenarios. Coordinating FX alongside legal milestones such as grant applications or inheritance tax payments protects the estate’s value and ensures beneficiaries receive more of what was intended. A planned, professional approach can preserve tens of thousands of pounds that might otherwise be lost to rate movement or poor timing.
Real Results That Prove the Difference
Property purchase:
A Dubai-based investor funding a UK property locked in their sterling rate two weeks before completion. When the pound strengthened by three percent, that forward planning saved nearly £9,000 compared with waiting until the deal closed. The transaction completed on time, with funds received and cleared exactly as planned. The currency dynamics between GBP and AED create similar opportunities for British buyers investing in Dubai property.
A Dubai-based investor funding a UK property locked in their sterling rate two weeks before completion. When the pound strengthened by three percent, that forward planning saved nearly £9,000 compared with waiting until the deal closed. The transaction completed on time, with funds received and cleared exactly as planned. The currency dynamics between GBP and AED create similar opportunities for British buyers investing in Dubai property.
Cross-border estate:
An executor managing assets across the UK and Dubai coordinated conversions to align with probate distributions and tax payments. By staging each transfer strategically, the estate preserved over £20,000 for the beneficiaries, value secured through precision rather than chance.
An executor managing assets across the UK and Dubai coordinated conversions to align with probate distributions and tax payments. By staging each transfer strategically, the estate preserved over £20,000 for the beneficiaries, value secured through precision rather than chance.
These examples highlight how currency timing and strategy directly influence legal outcomes. Whether it’s completing a purchase in London, distributing an estate from Dubai, or meeting a tax deadline, the right financial structure can turn a complex transaction into a smooth, efficient process.
Why It Matters
When clients move assets between the UK and UAE, every stage of the process carries financial risk. Exchange rates shift. Settlement delays happen. But with careful planning, those same variables become opportunities.
The solicitor safeguards the legality and structure of the transaction.
Lamera safeguards the value within it.
Lamera safeguards the value within it.
Together, the process becomes cleaner, faster, and more profitable, for you and your beneficiaries.
About Lamera Capital
Lamera Capital partners with solicitors, private clients, and family offices across the UK and UAE to manage currency transfers with precision and confidence.
Our purpose is simple: maximise value, minimise friction, and ensure every cross-border payment lands on time at the best achievable rate.
From property completions and probate distributions to inheritance transfers and tax settlements, we align financial timing with legal milestones, protecting both compliance and client wealth.
If you’re managing UK-UAE property, inheritance, or investment transactions, speak with Lamera Capital. We’ll help you plan each transfer so that your timing and exchange rates work for you, not against you.