Take one profile: a German engineer, ten years in Dubai, a salary account at a local bank, an apartment in the Marina, an old savings account in Frankfurt, and a share of the family house near Cologne that will arrive someday, because the parents are in their eighties. Put those assets on one spreadsheet and they look like one estate. Legally they sit in two systems. The Frankfurt account and the eventual share of the Cologne house answer to German succession law. The Dubai salary account and the Marina apartment answer to UAE process. Neither system asks the other's permission, and each has one rule that catches expats off guard.
The Pflichtteil, explained flat
German succession law allows a testator to write a close relative out of the will, and the will stands. The named heirs inherit, the land registry and the banks follow the document. Then the excluded relative presents a bill.
That bill is the Pflichtteil, the compulsory share. Three groups can raise it: the deceased's descendants, the spouse, and the parents when there are no descendants. The arithmetic runs in two steps. First, work out what the relative would have received had there been no will at all, under German intestacy rules. Then halve it. The result, expressed as a share of the estate's value, is owed to that person in money by the people the will actually names.
The form of the claim is the detail worth rereading. The claimant does not become co-owner of the flat in Munich or the portfolio in Frankfurt. The claimant becomes a creditor of the heirs, with a claim denominated in euros. Which moves the practical question for the heir from "who gets what" to "where does the cash come from". An estate can be asset-rich and cash-poor: a house, a stake in a family business, modest liquid savings. The heirs own all of it under the will, and they owe a payment they may have to borrow against the estate to make. German practice has developed ways of managing that pressure, from lifetime planning to negotiated settlements between relatives. The right approach belongs with a professional who has the file in hand.
If you know both countries, the contrast with Italy is instructive: Italy reserves fixed fractions of the estate itself for protected family members, while Germany converts the protection into a payment obligation. The side-by-side is here: fixed reserved fractions in Italy vs the German cash Pflichtteil claim.
Whether a specific relative can raise the claim in your family, against whom, and for how much depends on the file. That assessment sits with a Rechtsanwalt. The structure described above is the stable part.
The debt surprise
The second issue is debt. Under German law, accepting an inheritance can mean accepting the deceased's liabilities along with the assets. An heir can end up personally responsible for debts the family never knew existed: an old loan, a guarantee signed decades ago, a tax arrear.
The common-law instinct expects a different sequence, in which the estate settles its own debts before anyone receives a distribution. The German framework can put the heir in the deceased's legal position directly, assets and liabilities together. Whether to accept a given inheritance, in what form, and within what time limits needs prompt case-specific advice from a German lawyer.
The takeaway for an expat in Dubai is small and practical. If a letter about a German estate reaches you, treat the timing as part of the problem. Speak to a Rechtsanwalt before you sign or declare anything.
What the UAE side controls
The UAE runs the other half of the map on its own rules. Since Federal Decree-Law 41/2022 came into force in February 2023, a non-Muslim resident can register a will and direct UAE assets as that will states. Without a registered will, the estate goes through the default process, and UAE real estate is governed by UAE law regardless of what any foreign document says (Article 17 of the Civil Transactions Law). From 1 June 2026, under Federal Decree-Law 25/2025, UAE assets belonging to a foreigner with no heir become a charitable endowment (waqf) supervised by the competent authority.
The mechanics start at the bank. On notification of a death, UAE banks freeze the deceased's accounts, including joint accounts, and release funds against court documents. Without clear paperwork the freeze commonly runs 6 to 18 months, and the release runs through the court, with the paperwork moving fastest when the estate's documents are in order and slowest when heirs across two countries are assembling attested papers from scratch. What that means for a surviving spouse day to day, and what stays usable, is covered in why the joint account freezes too, and what a family can still use.
A registered will is the instrument that shortens the path. Two registries serve non-Muslim expats. The DIFC Wills Service operates in English, requires no UAE residency, and allows remote video signing; since Dubai Law No. 2 of 2025, the DIFC Courts hold exclusive jurisdiction over the enforcement of DIFC wills, with a direct enforcement writ. A DIFC Full Will costs AED 10,000 single and AED 15,000 for mirror wills (official fee schedule, difccourts.ae, 2026). ADJD registration is bilingual Arabic and English, costs AED 950 per will, so AED 1,900 for a couple registering one each, and is recognised across the seven emirates. Which route suits a German owner of a Marina apartment versus a family renting in Abu Dhabi is a separate decision, mapped in which registry route fits which profile.
For an uncontested estate with a registered DIFC will, the DIFC Courts' own FAQ describes probate in terms of a few weeks. The route without a registered will has no published timeline.
The two-will design, Germany edition
The working structure for a German expat with assets in both countries is usually two coordinated wills: a UAE will scoped to UAE assets, a German will scoped to German assets, each drafted so that neither revokes the other. The scoping is where do-it-yourself attempts fail. A later will carrying a routine "I revoke all previous wills" clause can silently cancel the other country's document, and the family discovers it during probate, at the worst possible moment to discover anything.
The temptation to run everything on the German will alone is understandable, and partly earned. A properly made German will comes from a system that takes succession seriously, and on the German side it does its job. The weakness is procedural rather than legal: a Dubai bank releases funds against UAE court documents, and moving a foreign will through attestation, legal translation into Arabic and court validation adds months, all of them inside the account freeze. The recognition question has its own guide: whether a home-country will is recognised for UAE assets.
On the EU side, one regulation does the routing. Regulation 650/2012, known as Brussels IV, applies the law of the deceased's habitual residence by default and lets a testator elect the law of their nationality in the will instead. This series has already explained the regulation twice, with worked examples, in the Italy guide and the France guide. This piece borrows the conclusion and moves on.
German succession practice also uses the Erbvertrag, a binding contract of succession. Instruments of that kind are recognised inconsistently outside the German legal family. How an existing Erbvertrag interacts with a new UAE will depends on the documents, so bring both to your Rechtsanwalt. There is also a European Certificate of Succession for cross-border paperwork inside the EU; two lines on it wait in the FAQ below.
The Two-System Map: Germany edition
One page, four boxes. Down the side, where the asset sits. Across the top, whether the UAE paperwork exists.
| Registered UAE will in place | No registered UAE will | |
|---|---|---|
| **UAE assets** (bank accounts, property, end-of-service benefits) | Distributed as the will directs under Federal Decree-Law 41/2022; on the DIFC route, uncontested probate is described in weeks (DIFC Courts FAQ) | Default process applies; UAE real estate follows UAE law (Article 17, Civil Transactions Law); account freeze commonly 6 to 18 months without clear documentation |
| **German assets** (accounts, property, business stakes) | Untouched by the UAE will when the two documents are scoped correctly; German law governs, including any Pflichtteil claims | The same German rules apply; the missing UAE document changes nothing on this side |
Registration changes the UAE column. A UAE will can shorten the local process from a range measured in months to uncontested DIFC probate described in weeks. German assets remain subject to German succession law, including the Pflichtteil claim and the debt question. Build the plan asset by asset and let each adviser work on the documents for that country.
The rest of the series sits under UAE inheritance by nationality, including how the UK's long-term resident rules keep a worldwide estate in tax scope for readers with a British chapter in their history.
Last updated: 23 July 2026 · Changelog: 2026-07-23: first published.
Frequently asked questions
Can I exclude a relative entirely under German law?
You can exclude them from the will, and the will remains valid. What German law preserves is the Pflichtteil: descendants, the spouse, and parents without descendants can claim half of their intestate share, in money, from the heirs. Exclusion on paper becomes, in practice, a reduced share plus an invoice. Whether anything stronger is possible in a specific case is a question for a Rechtsanwalt with the family file in front of them.
Does my German will cover my Dubai flat?
UAE real estate is governed by UAE law whatever the foreign document says (Article 17, Civil Transactions Law), and a foreign will faces a longer validation path before UAE authorities act on it. The full analysis is here: whether a home-country will is recognised for UAE assets.
Do heirs pay German tax on UAE assets?
Possibly, depending on who is resident where, what the asset is, and how it passes. German tax rules can reach cross-border estates. Take the asset list to a Steuerberater for the thresholds, rates and filing position that apply to the file.
What is the European Certificate of Succession?
A standard EU document that lets heirs and estate administrators prove their status across member states without repeating national procedures in each one. It is an EU instrument; the UAE process runs on its own court documents. Your Rechtsanwalt will know whether your file needs one.
Should I accept an inheritance with unknown debts?
Acceptance can carry personal responsibility for the deceased's debts. Speak to a Rechtsanwalt before responding to anything from a German court or estate, and take every document you received.
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