UAE Law and Practice Contributed by: Yann Mrazek, Kath Zagatti, Hermione Harrison and Keerthi Voodimudi, M/HQ Corporate Services Ltd
arrangements, and structures that can adapt to relo- cation, regulatory developments and international succession considerations. Industry-Specific Wealth Planning Industry concentration significantly influences suc- cession planning in the UAE, particularly where wealth is concentrated in illiquid or operating assets. This is common among families and entrepreneurs with substantial exposure to real estate, construction, hos- pitality, logistics and trading businesses. For real estate-heavy portfolios, legacy planning focuses on holding and transferring assets without forced sales. Structures are commonly used to cen- tralise ownership, separate economic benefit from day-to-day management and establish clear income distribution rules to preserve asset value and continu- ity. For operating companies, succession planning cen- tres on control and leadership. Arrangements typically address decision-making authority, leadership suc- cession and the separation of ownership and manage- ment to ensure business stability across generations. In sectors such as technology, healthcare, energy and professional services, succession planning extends beyond asset transfer to maintaining business func- tionality. These industries are often highly regulated and dependent on intellectual property or key indi- viduals, requiring planning that ensures regulatory continuity, protects intellectual property and mitigates key-person risk while supporting long-term wealth preservation. Evolving Client Expectations Across both established and emerging wealth pro- files, clients in the UAE increasingly expect succes- sion planning to deliver professionalised governance, robust asset protection and durable long-term struc- tures. Informal or purely reactive planning approaches are steadily giving way to more sophisticated, institu- tional-style frameworks. These expectations reflect the UAE’s position as a mature regional and international wealth hub. Suc- cession planning is increasingly viewed as a strategic
exercise that takes into account regulatory develop- ments, cross-border complexity, and multigenera- tional continuity, rather than as a one-time transfer of assets.
2. Residency and Domicile for Purposes of Wealth and Estate Planning 2.1 Determining Domicile
The concept of domicile is not central to UAE succes- sion or tax law in the way it is in many common law jurisdictions. UAE law does not generally rely on domi- cile as the primary connecting factor for inheritance, taxation or personal status matters. Instead, national- ity, religion, residence and the location of assets are The UAE does not impose estate tax, inheritance tax or personal income tax. Accordingly, domicile or habitual residence does not affect liability to wealth transfer taxation, as no such domestic tax regime exists. However, it is important to note that Corporate Tax (CT) may apply to the income generated by assets within an estate if these assets are held through a taxable entity or if the deceased was conducting a taxable business activity in the UAE. For individuals with cross-border connections, habitual residence may become relevant in determining tax residence under applicable double tax treaties where compet- ing jurisdictions assert taxing rights. In such cases, treaty tie-breaker rules may consider factors such as permanent home, centre of vital interests or habitual abode. These considerations arise from foreign tax systems rather than UAE domestic law. Governing Law of Succession and the Right to Make a Will In succession matters, domicile is not the principal connecting factor. For Muslim individuals, inheritance is governed by Sharia principles as codified in Federal Decree-Law No 41 of 2024 on Personal Status. For non-Muslims, Federal Decree-Law No 41 of 2022, as amended, permits the application of either the law of the principal determinants. Estate or Inheritance Tax
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