Wealthy individuals from the Middle East are increasingly using English law to make wills so they can temper the strictures of sharia law, which favours sons over daughters when it comes to inheritance.
Charlie Sosna, a partner at law firm Mishcon de Reya, said the Gulf rich liked this strategy as it allowed them to “work within the spirit of sharia but in a way that achieves what they want in their wealth and succession”, which can include more equal distribution of assets outside their home country between children.
In English law, testamentary freedom means those making wills can leave their assets to whoever they like almost without restriction. Sharia law, the moral and religious code of Islam, has precise rules about how much relatives receive. A daughter typically inherits half a son’s portion, for example.
The increasing use of English wills by Gulf families was in part a consequence of their children’s growing globalisation, said advisers.
Sosna pointed out one client who wanted his wealth to go to his son, but under sharia rules, the fortune would go to the client’s ex-wife if the son died. An English will could prevent this.
Oliver Piper, a partner at Farrer & Co, called this approach of moderating sharia rules by using English wills “sharia-lite”.
For more information see Josh Spero & Nicolas Parasie “Wealthy Gulf families look to London to make gender-balanced wills” Financial Times, July 29, 2026.