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Even though the Personal Status law of the UAE provides that foreigners may request the court for the application of their home country law, this law did not expressly amend the Civil Code of the country. This gave rise to the uncertainty of whether or not a non-Muslim and non-UAE national inheritance and wills will be subjected to Sharia law and not according to their own intentions as per their home country law.The procedure, cost and uncertainty in the outcome of the decision is what makes the expatriates/foreigners hesitant to invest in real property in the UAE.

Source: Rules of Succession in Dubai | Hassan Elhais – JDSupra

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