Russian Citizen With Property in the UAE? Why You Need a Separate UAE Will, Resident or Not

Real estate is generally treated as governed by the law of the country where it physically sits, regardless of the owner's nationality or residence. A will drafted under Russian law does not automatically extend to a Dubai or Abu Dhabi property, so Russian owners need a separate will registered through DIFC or Abu Dhabi's non-Muslim wills registry.

A Large Community, With a Common Gap

Russian buyers have been among the most active investors in Dubai real estate in recent years, whether relocating and holding UAE residency, or buying purely as an overseas asset from Russia. What the two groups tend to share is the same gap: no UAE-specific will covering the property, on the assumption that a Russian will, or Russian inheritance law generally, will simply carry over. It doesn't, for the same reason it doesn't for any other nationality.

Why a Russian Will Doesn't Reach the UAE Property

Real estate is generally treated as governed by the law of the country where it physically sits, regardless of the owner's nationality or where they live. A will drafted under Russian law, addressing your Russian assets and any obligatory-share entitlements for close relatives under Russian succession rules, is not automatically the document a UAE court or land department will act on for a Dubai or Abu Dhabi property. Residency status doesn't change this either, a Russian citizen who has relocated to Dubai and a Russian citizen who has never lived there but owns an investment apartment are in exactly the same position for that specific asset.

Without It: The Default Framework Applies

Absent a valid, UAE-recognised will, the property falls under the UAE's default succession framework for non-Muslims. Since February 2023, that default is a civil-law formula, broadly half to a surviving spouse and the rest split equally among children, which replaced the older Sharia-rooted default but is still a fixed formula rather than the "obligatory share" concept in Russian succession law, which reserves a minimum for specific dependants but otherwise leaves more room for a testator's own wishes. This can produce a distribution meaningfully different from what Russian law or your own intentions would produce, and it comes with the same practical friction: frozen assets and a court process your family navigates from a different country while it's unresolved.

Registering a UAE Will

For non-Muslim Russian citizens, this generally means registering through the DIFC Wills Service Centre or the Abu Dhabi Judicial Department's non-Muslim wills registry, both can generally cover UAE assets regardless of emirate, the meaningful difference is legal tradition and process, not geography. Both routes allow you to specify beneficiaries and, if relevant, guardians for children resident in the UAE (DIFC guardianship nominations specifically require the child to reside in Dubai or Ras Al Khaimah), and both are generally open to non-resident owners as well as UAE residents, confirm current eligibility for your situation directly with the registry or a UAE-licensed lawyer, as requirements are set by the registry and can change.

Keep the Russian and UAE Documents Aligned

Your Russian will, or the default rules that would otherwise apply under Russian law, should continue to address your Russian assets. The UAE will should be scoped specifically to the UAE property and any other UAE-connected assets, with executors on both sides who can realistically act. Sanctions-related banking restrictions can also complicate cross-border estate administration for Russian citizens in ways worth raising directly with your UAE-licensed lawyer, since the practical landscape here shifts and a general blog post is not the place to track it.

Talk to Vaksy about your estate plan →