Two jurisdictions, one estate — where wills contradict each other
A registered will in the Emirates governs your assets there. As soon as a second one exists in your country of residence, a question arises that neither answers on its own.
The article on the registered UAE will ends with a sentence that deserves its own treatment: the two wills must not contradict each other. That is where most arrangements come apart — not for want of a document, but because there are two of them, drawn up independently.
Why there are two in the first place
Succession law in many countries attaches to different criteria — sometimes last residence, sometimes nationality, and for real property frequently the place where it is located. Different law may therefore govern an apartment in Dubai than a securities account in Switzerland or a house in Germany.
This is not a flaw in the system; it is how it works. But it does mean a single document rarely covers everything.
Where the contradictions arise
Three patterns recur:
- The revocation clause that goes too far. Many will templates contain a sentence revoking all earlier dispositions. Draw up a second will later and you unintentionally cancel the first — including the one meant for another country.
- The double allocation. The same person is left the same asset in both documents, or two different people are left the same asset. What applies is then settled by a court, not by you.
- The executor without reach. Someone appointed in one country may have no authority in the other. Until that is resolved, dealings with the property stand still.
What follows from this
Have both wills drawn up by people who know about each other. Not necessarily by the same firm — but each side must have seen the other document and refer to it expressly, particularly in the revocation clause.
And revisit this whenever something changes: a move, a marriage, a birth, a further property in a third country. A pair that was aligned yesterday is not automatically aligned after a relocation.
This article is general orientation and does not constitute legal advice. Which law applies to your estate depends on your personal situation and the countries involved; that belongs in the hands of a lawyer — I am happy to make an introduction.
Keep checking
If you want to apply this to a specific plan, I am happy to assess it with you, or you can work through the twelve points before a purchase yourself.
