A will drafted for one jurisdiction rarely holds up cleanly in another. We build estate plans, wills, and powers of attorney designed from the outset to work across Malta and the UAE, so a client's wishes are enforceable wherever their assets end up.

A will drafted for one jurisdiction rarely holds up cleanly in another. Harry Reynolds, who leads our trusts, family, and private client work, builds estate plans, wills, and powers of attorney designed from the outset to work across both Malta and the UAE, so a client's actual wishes are enforceable wherever their assets, and their family, end up.

Malta's succession law follows EU norms and gives testators broad freedom to determine how their estate is distributed, subject to certain forced heirship protections for close family members. The UAE's approach has historically applied Sharia-based succession rules by default, particularly for Muslim residents, though recent reforms now allow non-Muslim expatriates in several emirates to opt into a civil succession framework more familiar to international clients, provided that election is made correctly and in advance.

This page covers how we build estate plans for clients with assets or family connections spanning Malta and the UAE, and the questions we hear most often from clients planning for this specific cross-border reality.

Wills Valid Across Multiple Jurisdictions

A single will covering assets in both Malta and the UAE needs to be drafted with genuine attention to how each jurisdiction's probate process will actually treat it, since a will perfectly valid under Maltese law may not automatically be given full effect over UAE-situated assets without the correct local election or registration having been made in advance.

We frequently recommend, and draft, parallel wills, one covering Malta assets and one covering UAE assets, coordinated carefully so they don't inadvertently conflict or revoke each other, giving a client clarity that each jurisdiction's assets will be dealt with according to a properly valid, locally recognised instrument.

Powers Of Attorney And Lifetime Planning

Beyond death, proper planning covers incapacity during life: lasting powers of attorney that let a trusted person manage a client's affairs, financial and, where relevant, medical, if they become unable to do so themselves. We draft these to be recognised and actionable in both Malta and the UAE, since a power of attorney valid only in one jurisdiction is of limited use if incapacity occurs, or assets need managing, in the other.

Lifetime gifting and wealth transfer planning, moving assets to the next generation during a client's lifetime rather than solely through a will, can also reduce future succession complexity and, depending on structure, offer genuine tax efficiency, and we build this into a comprehensive estate plan alongside the will itself.

Coordination With Tax And Corporate Structuring

An estate plan divorced from a client's underlying corporate and tax structure frequently fails to achieve what it sets out to do. Where a client's wealth sits substantially within companies, trusts, or foundations, the estate plan needs to address succession to those structures specifically, not just to personally held assets, coordinating directly with our corporate and tax colleagues to ensure the plan actually works as intended.

Family Office Estate Governance

For families with more complex, multi-generational wealth, we help establish formal governance frameworks, family constitutions, succession committees, and structured decision-making processes, that go beyond a single will or trust document to address how the family's wealth and business interests should actually be governed across generations and across the Malta-UAE corridor specifically.

Frequently Asked Questions