Middle‑Eastern wealth is increasingly turning to English law for wills, letting Gulf families sidestep sharia’s son‑preferring rules. Charlie Sosna of Mishcon de Reya says the approach lets them “work within the spirit of sharia but in a way that achieves what they want in their wealth and succession,” and he’s seen a clear uptick.

English testamentary freedom lets a testator leave assets almost without restriction, unlike sharia, where a daughter inherits half a son’s share. Hannah Wailoo of Withers notes an egalitarian trend, citing Gulf families with more daughters or only daughters who seek global solutions to protect their wealth.

Advisers point to a slightly westernised next generation with complex marital situations. Oliver Piper of Farrer & Co. calls this “sharia‑lite” – a moderated approach. The Iran conflict has also pushed Middle‑Eastern estates to rethink asset‑holding structures, according to Jonathan Burt of Charles Russell Speechlys.

Trusts, especially in Jersey, are another popular tool. Jersey figures show Gulf clients rose to 11.8% of non‑Jersey beneficiaries in 2024. Wailoo says trusts allow precise beneficiary control, while Laura Uberoi notes the trend began a generation ago, and Simon Malkiel warns the strategy may fail if contested.