Not legally. But if you are a non-Muslim British expat in Dubai and own assets in England and Wales, a will made under English law for those assets may make it simpler for them to pass as you want. Many expats have two wills, one registered in the UAE and one for UK assets, drafted to work together rather than cancel each other out. This reflects UK and UAE rules as at October 2026.

What happens if you only have a UAE will

A will registered in the UAE can, in principle, cover assets anywhere. The DIFC wills service, for example, has allowed wills to cover UAE-wide and worldwide assets since 2019.

The difficulty is practical. To deal with assets in England and Wales, such as a house or bank account, your executors will normally need a UK grant of probate, and the probate registry will need to accept the foreign will. Under the Wills Act 1963, a will is treated as properly executed if it followed the law of the place where it was signed, or of your domicile, habitual residence or nationality. A foreign will can still mean extra steps, such as certified translations or evidence of foreign law, which may add time and cost.

A will drafted for UK assets, in the form UK executors and banks expect, may avoid much of that.

What happens if you only have a UK will

The reverse problem applies in the UAE. A UK will may not be straightforward to rely on for UAE assets. UAE banks commonly restrict access to a deceased person's accounts until they receive a court order, and UAE property transfers go through local processes. Without a locally registered will, your family may face a slower route through the UAE courts.

For non-Muslims, Federal Decree-Law No. 41 of 2022 on civil personal status sets default rules: without a will, a surviving spouse takes half the estate and the children share the other half equally. Heirs can also ask for the law of the deceased's home country to apply. Neither default may match what you actually want, particularly in a blended family or where you want assets held for young children.

What happens if you have no will at all

You may face two sets of default rules at once. UAE assets may follow UAE succession law. UK assets may follow the intestacy rules of England and Wales, Scotland or Northern Ireland, depending on the type of asset, where it is and your domicile. Under the rules for England and Wales, unmarried partners do not inherit and stepchildren have no automatic share. A will in each country lets you decide, and lets you name guardians for children.

Probate and confirmation procedures differ between England and Wales, Scotland and Northern Ireland.

Making two wills work together

If you have two wills, a few details matter:

  • Revocation clauses: many wills start by revoking all earlier wills. A new UAE will with a standard clause could accidentally revoke your UK will, or the other way round. Each should be limited to its own assets.
  • Consistency: executors, beneficiaries and any trusts should line up across both documents.
  • Guardianship: the guardian named for minor children should be the same in both.
  • Review together: when you update one, check the other.

A will does not, by itself, determine your UK inheritance tax position, which depends on your residence status, where your assets are and the reliefs available. See our guide on inheritance tax for UAE resident UK nationals. A well drafted will can, however, help make sure exemptions such as the spouse exemption are not wasted.

A worked example

Illustrative example only, not a real client.

Mark and Claire, both non-Muslim British nationals, live in Dubai with two children aged 8 and 11. They own:

  • A Dubai apartment worth AED 2,000,000 and UAE bank accounts
  • A rental flat in England worth GBP 350,000
  • A UK investment account worth GBP 100,000

They register DIFC wills covering UAE assets and appointing guardians. They also each have an English will covering UK assets only, with matching executors, a trust for the children until age 25, and the same guardians.

If Mark dies, his executors deal with the Dubai assets through the DIFC process. In England, the executors apply for probate using an English will in the form the registry and UK banks expect. Assuming both wills were drafted with limited revocation clauses, neither revokes the other.

Common mistakes

  • Signing a new will in one country that revokes the will in the other
  • Assuming a UK will is enough to release UAE bank accounts quickly
  • Naming different guardians or executors in each will
  • Not reviewing wills after marriage, divorce, a new child or selling property

A regulated financial adviser can help. Wills themselves should be drafted by a qualified lawyer in each relevant country. Get in touch for a free introduction.

Sources and further reading

Last reviewed: October 2026. Tax year: 2026/27; UAE law as at October 2026. Jurisdictions covered: England and Wales, UAE. Rates, legislation and guidance change, so recheck before relying on this. Rules can differ between England and Wales, Scotland and Northern Ireland; tax residence is fact-specific; treaty outcomes depend on residence, domicile or nationality provisions; examples are simplified and omit reliefs, costs, exchange rates and anti-avoidance rules. This is general information, not financial, tax or legal advice. Take advice in the relevant country before acting.