For many expatriates living in the UAE, their life and assets are not limited to one country.

You may live and work in the UAE while owning a property in USA, maintaining a bank account in the UK, holding investments in another country or having a business interest overseas.

This creates an important estate-planning question:

“If I have a UAE Will, will it automatically cover everything I own around the world?”

The answer is: not necessarily.

When you have assets in different countries, estate planning can become more complicated because each country may have its own inheritance laws, court procedures and requirements.

Why Do Cross-Border Assets Matter?

A Will is intended to set out your wishes about what should happen to your estate after your death.

However, when your estate includes assets located in different countries, the law of the country where a particular asset is located may also become relevant.

For example, the process for dealing with a property in the UAE may be different from the process for dealing with a property located in India.

Similarly, a bank account or investment held in another country may be subject to the rules and procedures of that country.

This means that simply having one Will does not necessarily make the administration of your entire worldwide estate straightforward.

Your UAE Will and Overseas Assets

A UAE Will can provide an important part of your estate-planning arrangements.

However, whether it can effectively deal with an asset located outside the UAE depends on several factors, including the type of asset, where it is located and the laws of that jurisdiction.

The relevant foreign jurisdiction may require its own probate, succession or recognition process before the asset can be transferred to your beneficiaries.

Does This Mean You Need Two Wills?

If you have assets in different countries, having separate Wills is generally recommended.

There is no one-size-fits-all approach to cross-border estate planning. Different countries have different inheritance laws, succession procedures and requirements for recognising and enforcing Wills.

For this reason, a Will prepared for your UAE assets may not be the appropriate document to deal with assets located in another country.

At Firm Advice, we generally recommend having separate Wills for assets located in different jurisdictions, where appropriate, so that each Will can be prepared in accordance with the laws and requirements of the country where the relevant assets are located.

This does not mean you should simply make multiple Wills independently. The Wills must be carefully coordinated so that one does not unintentionally revoke or conflict with another.

A Simple Example

Imagine you live in the UAE and have:

• An apartment in Dubai

• A bank account in the UAE

• A house in India

• Investments in the UK

Your UAE assets can be addressed through your UAE Will, while your assets in India and the UK may require separate estate-planning arrangements in accordance with the laws and procedures applicable in those countries.

Your family may therefore need to follow different legal processes to deal with different parts of your estate.

The key is to plan your estate jurisdiction by jurisdiction, while ensuring that all your Wills and estate-planning documents work together.

At Firm Advice, we do not recommend using a single Will without first considering the laws governing your assets in each country.

What If You Already Have a Will in Your Home Country?

This is very common among expatriates.

You may already have a Will in your home country before moving to the UAE.

That does not necessarily mean you should simply rely on that document for your UAE assets.

Similarly, making a UAE Will does not necessarily mean your existing foreign Will should be ignored.

The two arrangements should be reviewed together to determine whether they work consistently and whether they cover the assets you intend them to cover.

Be Careful When Making More Than One Will

Having multiple Wills can sometimes be useful for someone with a genuinely international estate.

But there is an important consideration:

One Will should not accidentally cancel another.

For example, if a new Will contains a broad clause revoking all previous Wills, it could potentially affect an earlier Will that was intended to continue covering assets in another jurisdiction.

This is why multiple Wills should be drafted with care and with the different jurisdictions in mind.

Keep Your Estate Plan Coordinated

Cross-border estate planning is not simply about having more than one document.

It is about making sure that all your estate-planning documents work together.

If you have a UAE Will and another Will in your home country, both should be reviewed carefully to ensure that they do not unintentionally conflict.

Similarly, if you acquire a new overseas property or investment, you should consider whether your existing arrangements still reflect your wishes.

What If You Move Between Countries?

Expatriates often move for work, family or business.

If you move from the UAE to another country, or from one country to another, your estate plan may need to be reviewed.

The same applies if you:

• Acquire property overseas

• Sell an overseas property

• Open foreign bank accounts

• Start or acquire an overseas business

• Move your permanent residence

• Change your beneficiaries

• Get married or divorced

• Have children

These changes do not necessarily mean that you need a new Will, but they are good reasons to review your existing estate plan.

One Estate. Multiple Countries. One Clear Plan.

A properly considered estate plan can help identify your assets, clarify your wishes and reduce uncertainty about the legal processes that may be required in different countries.

If you have assets in the UAE as well as another country, we can help you understand how your UAE Will fits into your wider estate-planning arrangements.

Your assets may be spread across countries. Your estate plan should bring them together.

At Firm Advice, we assist UAE residents and expatriates with Will drafting, estate planning, beneficiary planning and reviewing existing Will arrangements.