Guide · updated 31.07.2026 · 13 min read · Lucent Legal team

Inheritance Across the UAE and Your Home Country: How Two Estates Actually Work

If someone dies leaving a flat back home and a bank account or property in Dubai, the family's first hope is usually "let's just settle this once, for everything." That hope doesn't survive contact with reality. There's no single "global" probate process: assets in the UAE and assets back home are handled separately, by different authorities, under different rules, and on completely different timelines. Below is how both proceedings actually work, what has to be legalized on each side, why lawyers on both ends recommend two separate wills instead of one, and the mistakes that most often cost a family extra months. Russia is used throughout as the clearest documented example — the general shape (separate estates, no shortcut, legalization instead of apostille) applies to most home countries, though the specific deadlines and fees below are Russia's.

Why There's No Single "Global" Estate

Back home, probate is opened wherever the deceased last lived, and it only reaches assets that are physically or legally located there — property, local bank accounts, shares in local companies. Whatever authority handles that (a notary in Russia, a court elsewhere) has no jurisdiction and no tools to touch a Dubai property or bank account — any certificate it issues is valid at home and won't be automatically recognized by a bank or land department in Dubai.

The UAE side works the same way in reverse. A UAE Personal Status court (or DIFC Courts, if a DIFC will was registered) only distributes assets located in the UAE — property, accounts at local banks, shares in UAE-registered companies. A flat or bank account back home falls outside that court's jurisdiction entirely; it's never even mentioned in the case.

The result: a family with assets on both sides runs two separate proceedings at the same time — one at home, one in a UAE court or DIFC. This isn't bureaucratic overkill, it's a consequence of the fact that inheritance law and jurisdiction are territorial almost everywhere: each country settles the fate of assets on its own soil under its own rules. If there's no will at all, how shares get split among non-Muslim expats in the UAE is covered separately in inheritance in the UAE without a will.

Home-Country Probate: Deadlines and Fees (Russia as the Documented Case)

In Russia, probate opens with a notary at the deceased's last place of residence, and the deadline to remember is strict: heirs must accept the inheritance within 6 months of the date of death — set directly by Civil Code Article 1154. Missing the deadline doesn't automatically forfeit the inheritance, but restoring the right requires going to court and proving a valid reason for the delay, which is its own slow process.

Once the 6 months pass and the circle of heirs is settled, the notary issues a certificate of inheritance, for which a state fee applies: 0.3% of asset value (capped at RUB 100,000) for first- and second-tier heirs — spouses, children, parents, siblings — and 0.6% (capped at RUB 1,000,000) for everyone else. There's no separate "inheritance tax" in the ordinary sense in Russia; it was replaced by exactly this fee back in 2006.

For an heir living in the UAE, the notary steps back home add a practical hassle: filing the acceptance and arranging power of attorney for a representative are often easier to do through a home-country consulate in Dubai, or by proxy, than flying back for every step. The Russian version of this guide walks through that consular route in full detail, for readers who need it.

Inheritance in the UAE: Courts, DIFC, and Local Assets

If the deceased had a registered DIFC will (or ADJD will), the UAE side runs through DIFC Courts (or the ADJD Wills Service) — generally more predictable and faster than a case with no will. Without a UAE will, distribution goes through the Personal Status court, and non-Muslim heirs default to the civil regime under Federal Decree-Law No. 41/2022 rather than Sharia — the detailed share breakdown and procedure are covered in inheritance in the UAE without a will.

There's no fixed statutory timeline for a UAE inheritance case — government sources don't publish one. Practicing lawyers estimate a case with a registered will can take a few months, while one without a will, in a disputed family situation, can stretch to a year and a half. Keep that next to Russia's hard 6-month deadline: the two proceedings aren't just independent, they run at completely different speeds, and a family has to manage both at once, not one after the other.

Separately, remember that the deceased's UAE bank accounts freeze automatically the moment a bank is notified of the death, and stay frozen until a court order distributes the assets — this happens whether or not there's a will. How that freeze works and how to lift it is covered in frozen bank account after death in the UAE.

Legalizing Documents Both Ways

The core documents — the death certificate and the certificate of inheritance — need to be recognized in both places, and an apostille doesn't work between the UAE and countries like Russia: the UAE isn't part of the 1961 Hague Convention, covered in detail in apostille in the UAE. Full consular legalization on both ends is required instead, and the exact chain of stamps and offices depends on your home country's own consular setup. If a full step-by-step for your country isn't something this guide covers, document legalization UAE walks through the general process and typical rejection reasons. The same applies to the certificate of inheritance itself: a document issued back home only gets accepted by a UAE court or bank after the equivalent legalization, never on the strength of the original alone.

Why Two Wills Is the Standard Advice

Lawyers who specialize in cross-border estates are consistent on this: for anyone with assets in more than one country, the right approach is a separate document for each jurisdiction with meaningful assets, not one will meant to cover everything. For the UAE, that's a DIFC will or ADJD will; for assets at home, it's a standard will valid under your home country's law.

The reason isn't excess caution — it's how the two systems actually work. A DIFC will only covers UAE assets and is drafted under common law rules; a will made under your home country's civil code only covers assets there. A single will written to satisfy one country's rules may not be recognized (or may be recognized only partially) by the other jurisdiction's court — and in a worse case, a later will in one country can be read as revoking an earlier one made elsewhere, unless the text explicitly says otherwise.

The practical fix international estate-planning sources recommend: state explicitly in each will that it applies only to assets in that specific jurisdiction and doesn't revoke wills made for other countries. That removes the basis for a dispute over which document controls, and lets both proceedings run in parallel instead of one blocking the other.

Taxes: None in the UAE, Nuances at Home

The UAE has no inheritance tax and no estate tax for individuals — this applies to assets located in the Emirates regardless of the heir's nationality. But the absence of a UAE tax doesn't release an heir from tax obligations in their own country of tax residence: if the heir is a tax resident of Russia (or any other country that taxes inheritance or worldwide income), local rules apply to them regardless of where the asset physically sits.

In Russia specifically, as noted above, there's no inheritance tax in the classic sense — just the notary's fee for the certificate. One detail people often miss: if inherited property (a flat, a car) is later sold, the heir may owe personal income tax on the sale — the minimum holding period for a tax exemption on inherited property is counted from the date of death, not the date the certificate was issued. The exact calculation for your situation — residency status, citizenship, and asset mix — is worth confirming with a tax advisor rather than assuming a general rule applies.

Common Mistakes

• Assuming one will covers everything. A will drafted under only one country's rules may not cover assets elsewhere, or may be recognized there only with reservations — hence the advice for two separate documents.
• Missing the home-country deadline while focused on the UAE case. In Russia that's 6 months. Both proceedings run in parallel and need attention at the same time, not one after the other.
• Using an apostille instead of consular legalization. An apostille doesn't work between the UAE and countries like Russia in either direction — this is the single most common, and most time-expensive, mistake at the seam between the two systems.
• Not accounting for the UAE account freeze. It happens regardless of the will or the status of the home-country case — a family should plan for the fact that access to money in the Emirates won't appear automatically before a court order.
• Relying on verbal agreements about "who gets what." With no will, each jurisdiction applies its own statutory distribution scheme, which may not match what the family expected — in the UAE or at home.

This material is for information only and is not legal advice. UAE law changes — a lawyer will assess how it applies to your situation.