DIFC vs ADGM: Which Wills Service Suits You?
The Dubai International Financial Centre and the Abu Dhabi Global Market both operate independent common-law jurisdictions within the UAE, and both offer a Wills service to non-Muslim residents and asset-holders. For most clients, either will achieve the desired result. For some, the distinction matters.
The DIFC Wills Service, launched in 2015, is the older and more widely used of the two. Its registry is located in Dubai, its courts conduct proceedings in English, and its Will templates have been refined over a decade of practical use. For clients whose principal assets are in Dubai or the northern Emirates, it is the natural choice.
The ADGM Wills Service offers comparable common-law protection, with a registry in Abu Dhabi. For clients whose interests are concentrated in the capital, or who hold ADGM-registered company shares, registration there may simplify both administration and any subsequent probate.
The practical differences are modest: registration fees, the location of any in-person attestation, and the seat of the court that would ultimately interpret the document. The decision is rarely a difficult one, but it benefits from being made deliberately rather than by default.
Written by the solicitors of LEX Services for the senior expatriate reader.
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