Inheritance in the United Arab Emirates: What’s the Difference Compared to France?
Expatriates and investors should be aware of the major differences between the inheritance systems of France and the United Arab Emirates. Adding to that, the taxation and administrative fees — often overlooked — can have a significant impact on how wealth is transferred.
Legal Framework of Inheritance
In France
Inheritance law is based on the Civil Code, which protects “reserved heirs” such as children and spouses.
A portion of the estate (known as the quotité disponible) can be freely allocated, but children cannot be entirely disinherited.
In the United Arab Emirates
Sharia law applies by default to Muslims.
Since 2020, non-Muslim expatriates have been allowed to create official wills (for example through the DIFC Wills Service Centre) to ensure their estates are governed by the laws of their home country.
If no registered will exists, local rules automatically apply — which can lead to unexpected consequences for those unfamiliar with Sharia law.
Inheritance Taxes and Fees: France vs. the UAE
France
Inheritance is taxable, with progressive rates depending on the degree of kinship:
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Children: 5% to 45% after an allowance of €100,000 each
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Siblings: 35% to 45% after an allowance of around €15,932
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Nephews/Nieces: 55% after an allowance of about €7,967
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Non-relatives: 60% after a very small allowance (approx. €1,594) (Sources: Blevins Franks, Wikipedia)
Transfers between spouses or PACS partners are fully exempt (Blevins Franks).
Inheritance taxes represent around 13.6% of all mandatory contributions in France, the highest rate in the European Union (Le Monde).
On top of that, notary fees are often around 10% of the total estate value (Reddit).
United Arab Emirates
There are no inheritance or estate taxes in the UAE (The Dubai Navigator, ANAROCK Middle East).
There is also no capital gains tax on transferred property (ANAROCK Middle East).
However, administrative fees may apply, such as:
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Court or judicial fees for validating an estate or executing a will,
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Fees for property appraisal or asset valuation,
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Translation or document authentication costs,
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Transfer or title withdrawal fees.
These fees vary depending on the complexity of the estate and the emirate where it is processed (Generis Global Legal Services).
Comparison Table: France vs. UAE
| Criteria | France | United Arab Emirates (UAE) |
|---|---|---|
| Inheritance Tax | Yes – up to 60% depending on kinship (Blevins Franks, Le Monde) | No – no inheritance or estate tax (The Dubai Navigator, ANAROCK Middle East) |
| Tax Allowances | Yes (e.g. €100,000 per child; lower for others) | Not applicable – no tax based on family ties |
| Notary/Administrative Fees | Yes – about 10% of estate value (Reddit) | Yes – court and administrative fees (Generis Global Legal Services) |
| Applicable Law Without a Will | French law applies automatically | Sharia law applies; non-Muslims should record a will to avoid this |
Practical Advice for French Expatriates
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Draft and register a will in Dubai or Abu Dhabi, specifying that French law should govern your estate.
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Plan for fees:
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In France: expect inheritance tax + notary fees (~10%).
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In the UAE: expect variable administrative or court fees.
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Consult an international inheritance specialist familiar with both French and Emirati regulations.
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Assess your tax residency to determine whether your global estate will be subject to French inheritance tax.
The Dubai Life: Your Partner in Managing Estate Planning
The Dubai Life offers comprehensive guidance for French-speaking expatriates wishing to secure and organize their estate in the UAE.
Its services include:
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Drafting and registering wills with local authorities (e.g., DIFC),
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Coordination with international lawyers and certified notaries,
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Fiscal preparation to reduce or eliminate French inheritance tax,
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Management of local administrative and legal formalities.
With expert knowledge of Dubai’s legal framework and the expectations of international investors, The Dubai Life helps expatriates protect their assets and simplify the transfer process for their heirs.
Conclusion
The difference is clear: in France, inheritance is heavily taxed, with rates reaching up to 60% depending on the family relationship. In contrast, the United Arab Emirates imposes no inheritance tax at all, though certain administrative costs may apply.
For expatriates, anticipating these differences is essential. By preparing a registered will and seeking professional guidance, you can protect your family and ensure the smooth, efficient transmission of your assets.
