GCC Inheritance Laws Define Estate and Wealth Transfer Regulations for Expatriates

Estate distribution across the six Gulf Cooperation Council (GCC) member states depends on the deceased's nationality, religion, asset jurisdiction, and whether a registered will exists, Forbes Middle East reported. Millions of expatriates holding cross-border real estate, corporate entities, and investments face distinct legal frameworks across each member state.

In the UAE, non-Muslim inheritance is governed by Federal Decree-Law No. 41 of 2022 on Civil Personal Status. In the absence of a registered will, 50% of the estate passes to the surviving spouse, while the remaining half is distributed equally among children regardless of gender. Expats can record wills via Dubai International Financial Centre (DIFC) Courts or civil will registries in Abu Dhabi.

Saudi Arabia's Personal Status Law permits non-Muslim and Muslim bequests by will, but restricts allocations to no more than one-third of the estate unless remaining heirs consent. If an existing legal heir is named in the will, all other heirs must ratify the bequest following the deceased's death. Cross-border asset transfers may require documentation across multiple jurisdictions.

Under Kuwait's Personal Status Law, Muslims and non-Muslims cannot inherit from one another, though non-Muslim wills and intra-faith inheritances are recognized through Ministry of Justice proceedings. Bahrain applies the deceased non-Muslim foreign national's home-country law to determine legal heirs and shares, while property transfers proceed via the Survey and Land Registration Bureau. In Oman, court-issued inheritance certificates allow property registration to legal heirs, and Qatar permits non-Qataris to inherit one residential property of up to 3,000 square meters outside designated foreign-ownership areas if they reside in the country.