A flat, but no keys
Take Andrei’s family. He was 58 and owned a construction company in Moscow. In 2021 he bought a flat in Dubai Marina for around AED 2.4 million, obtained a residence visa and in recent years split his time between two cities: winters in the Emirates, the rest of the year in Moscow. The story is a composite, with invented names and figures, but files like this have long been no rarity on our desks.
In spring 2026 Andrei died in Moscow. He had left no will, either in Russia or in the Emirates; he kept meaning to “sit down and write it calmly”. He was survived by his wife Olga, an adult son and daughter, and his mother, who is over eighty. Under the marriage agreement, all foreign assets were recorded as the husband’s separate property, so the question of a spouse’s share did not arise.
A week later Olga tried to transfer money from her husband’s account at a Dubai bank, which held around AED 900,000. The account turned out to be frozen, even though Olga was a joint holder.
What follows is something people in Moscow rarely think about.
Which law decides: the view from Moscow
Let us start with the Russian Civil Code, since the family goes to its own notary first. Article 1224 works like this: succession as a whole is governed by the law of the country where the person last lived, while real estate is inherited under the law of the country where it is located. For the Dubai flat the answer is immediate: UAE law applies, and a Moscow notary cannot change that.
The account is more complicated. Money in an account counts as movable property, so everything turns on Andrei’s last place of residence. Where did he live: in Moscow, where he was registered, or in Dubai, where he spent the winters and held a visa? If the Emirates are recognised as his last place of residence, their law would formally extend to his Moscow deposits and his stake in an LLC as well.
This is not just theory: in 2024 the Constitutional Court examined a similar situation (Resolution No. 12-P). A Russian citizen died in Germany, where he had been living, while his accounts and car remained at home, and the notary sent his daughter to the German authorities. The Constitutional Court corrected this: if the heir has no other way to exercise their rights, a Russian notary cannot refuse to process movable property in Russia merely because foreign law applies to it.
Andrei was registered in Moscow, and the notary opened the probate file there. The six months for accepting the inheritance kept ticking, regardless of what was happening in Dubai.
Inheritance in the UAE for non-Muslims: Law No. 41/2022
Now the view from Dubai. Since 1 February 2023, Federal Decree-Law No. 41/2022 on Civil Personal Status has been in force in the Emirates. It applies to non-Muslims: UAE citizens and foreigners living in the country. Previously, the courts applied Sharia to inheritance by default, and a foreigner who wanted to avoid this had to make a separate request for the law of their own country to apply.
If there is no will, half of the estate goes to the surviving spouse and the other half is divided equally among the children, with no distinction between sons and daughters. Parents inherit only if there are no children, and brothers and sisters stand further back still.
For Olga this is favourable: AED 1.65 million out of AED 3.3 million, with AED 825,000 each going to the son and daughter. Under this scheme, Andrei’s mother receives nothing.
Russian law divides the estate differently. Children, the spouse and parents are all heirs of the same, first, order of succession, so with the same AED 3.3 million each of the four would receive AED 825,000. Olga would lose exactly half of her share.
Here is the catch. Law No. 41/2022 allows any of a foreigner’s heirs to ask the court to apply the law designated by the UAE conflict-of-laws rules, if there is no registered will. For a foreigner, that is usually the law of their nationality. This is exactly the idea that Andrei’s younger brother brought to his mother.
Will such a request extend to the flat? Frankly, the question is open. Real estate in the Emirates has traditionally been governed by local law, Russia’s Article 1224 also refers the flat to UAE law, and since 2026 the country has had a new Civil Code; how the courts will read its conflict-of-laws rules in inheritance cases is not yet entirely clear. As regards the money in the account, the mother’s position is stronger.
If the deceased was a Muslim
Everything said above applies only to non-Muslims. For Muslims, a different act applies in the Emirates: Federal Decree-Law No. 41/2024 on Personal Status. It came into force on 15 April 2025 and replaced the 2005 law. It is based on Sharia rules, under which a person’s share depends on the degree of kinship and on gender, so that a daughter, for example, receives less than a son.
For Russian families this is nothing exotic. Religion is not stated in a passport, but in an Emirati inheritance case the question is far from a formality, and families from Tatarstan or the Caucasus should clarify it before counting on the “half to the wife, half to the children” scheme. Incidentally, a DIFC will, discussed below, is not available to a Muslim.
Documents: why an apostille will not help
The familiar apostille is no use for the Emirates. The UAE is not a party to the 1961 Hague Convention.
That means consular legalisation. Death and marriage certificates and the children’s birth certificates go through a chain: the Consular Department of the Russian Ministry of Foreign Affairs, the UAE Embassy in Moscow, and then the UAE Ministry of Foreign Affairs. In Moscow this means a RUB 350 fee per document and three working days, if you manage to get an appointment. Then comes translation into Arabic by a translator licensed by the UAE Ministry of Justice, since the Dubai courts work in Arabic.
Russia has no treaty with the Emirates on legal assistance in civil matters. In the Supreme Court’s list as of August 2026, the UAE has only one bilateral treaty with Russia, and it has nothing to do with inheritance. A Russian court judgment will not be enforced automatically in Dubai: recognition there is based on reciprocity and requires separate proceedings. For an inheritance, it is usually wiser to go straight to a Dubai court.
If a Moscow notary has already issued a certificate of inheritance, it also makes sense to legalise it. On its own it will not transfer the Dubai flat, but it may be useful to the court as an official document confirming who the heirs are.
A UAE bank account after the owner’s death
An account freeze in the Emirates is neither a penalty nor a bank error. A bank freezes accounts, joint ones included, as soon as it learns of a client’s death, and keeps them frozen until a court decides who is to be paid and how much.
Since July 2023, a dedicated division for non-Muslim inheritance has operated within the Dubai inheritance court. A case can be opened without a will: what is needed is an official document setting out the heirs and their shares, or a court decision confirming the death and the circle of heirs. A document issued outside the Emirates is accepted only once legalised.
A will made outside the Emirates, for example before a Moscow notary, can also be executed through a Dubai court: the applicant attaches a certified copy of the law governing the will, usually the law of nationality. The court itself says it aims to resolve such cases in a single hearing.
What should have been done during his lifetime
The most underrated document for anyone who owns assets in the Emirates is a local will. Once registered, it settles the question of applicable law and leaves no room for the kind of request Andrei’s brother came up with.
The best-known option is the Wills Service at the DIFC Courts, the courts of Dubai’s financial centre. It offers wills for non-Muslims, in English and built on common-law logic. Dubai Law No. 2/2025 on the DIFC Courts confirmed their exclusive jurisdiction over such wills and their power to enforce them in respect of assets both inside the centre and beyond it. Under the published tariff, registering a full will for one person costs around AED 10,000, with the lawyer’s work charged separately.
Abu Dhabi has ADGM. There, a non-Muslim’s will is not registered but notarised: the text is in two languages, Arabic and English, with a fee of AED 950 payable to the Abu Dhabi Judicial Department and $155 to ADGM. ADGM has no probate proceedings of its own; after death, the case is handled by the same Judicial Department.
A will can also be made in the courts of Dubai itself, under Emirate Law No. 15/2017. The document will be in Arabic, but it will be executed by the very court that later divides the estate.
And something people rarely remember: the Emirati will and the Moscow will must not contradict each other, or the heirs will end up with two documents and one big conflict.
Where heirs should start
If the person has already died, the work runs in parallel: in Moscow, the notary and the six-month deadline; in Dubai, the court; and between them, the legalisation of documents.
Pauses are what cost the most. The family waits for the Moscow certificate, then learns about legalisation, then about the Arabic translation, and six months go to waste. How we organise inheritance proceedings abroad is described separately. In one matter we handled an inheritance in three countries at once, including accounts in the UAE; the details are in our case on an inheritance in 3 countries. The general rules on applicable law and time limits are collected in our analysis of inheritance abroad, and other materials are in the Insights section. We agree the plan and the cost of the work in writing before we start.
In Andrei’s case, it never came to a long dispute. The heirs agreed that the flat would be divided under the Emirati scheme and the money in the account equally among the four of them, and presented the court with an agreed division. There is no inheritance tax in the Emirates, so there was none to pay.
Frequently asked questions
Is a Russian certificate of inheritance valid in the UAE?+
Not on its own. A flat and an account in the Emirates are transferred on the basis of a local court decision, and Russian documents are submitted there with consular legalisation and an Arabic translation.
How is an estate divided in the UAE without a will if the deceased was not a Muslim?+
Under Law No. 41/2022, half goes to the spouse and the other half is shared equally among the children. But if there is no registered will, any heir of a foreigner may ask the court to apply a different law, usually the law of nationality.
Do Russian documents need an apostille for the UAE?+
No, the Emirates are not a party to the Hague Apostille Convention. Consular legalisation is required (the Russian Ministry of Foreign Affairs, the UAE Embassy in Moscow, the UAE Ministry of Foreign Affairs), followed by translation into Arabic.
Need an assessment of your situation?+
Leave a request: an international inheritance lawyer will review the documents for your assets in the Emirates and in Russia and tell you where the main risk lies now and which deadlines are already running.