High Net Worth Marriage

Senior legal guidance on matrimonial regimes and cross-border marriage in the UAE, protecting your assets, rights and family future.

Matrimonial Regimes & Applicable Laws

We provide critical analysis of applicable matrimonial property laws to determine how your assets will be divided upon divorce in the UAE.

In-depth description

This highly technical advisory service is the cornerstone of any international marriage or partnership. When couples move across borders, the question of which country’s law governs their assets — community of property or separation of property — is rarely straightforward.

We analyze your marital history and circumstances to determine which legal regime currently applies to your assets, and advise on the choice of law for your marriage — a decision that can be made even years after the ceremony. This choice fundamentally shapes your family’s financial life, from how joint assets are managed during the marriage to how they would be divided in the event of a separation or divorce.

This service is particularly critical for expatriates in the UAE, where the intersection of French law, Shari’ah principles, and international private law creates real complexity. Getting this right early protects both spouses and prevents costly disputes later.

Scope of work

  • Conduct a detailed analysis of the couple’s marital history, nationalities, and domiciles.
  • Research and review the matrimonial property laws of all relevant foreign jurisdictions.
  • Provide a formal legal memorandum determining which country’s law governs the couple’s assets.
  • Advise on the strategic choice of applicable law for the marriage and eventually for divorce proceedings, explaining the financial impact of each option.

Price range

AED 8,000 to AED 35,000 (hourly fee)

Deliverables

A formal Legal Opinion Memorandum on the applicable matrimonial regime and choice of law.

Is your international marriage truly protected?

Did you marry across different countries?

The law governing your assets may not be the one you expect, with major consequences on divorce.

Do you hold assets in multiple jurisdictions?

Cross-border ownership requires careful legal analysis to avoid costly surprises during a separation.

Are you planning to relocate internationally?

Moving countries can change which legal regime applies to your assets, sometimes without you knowing.

Have you ever reviewed your matrimonial regime?

Most couples never have this analysis done. It is one of the most important legal steps you can take.

Frequently asked questions

International private law determines which country’s legal rules govern your marriage, including asset division, divorce grounds and financial obligations. For internationally mobile couples, this analysis is non-trivial, and the outcome can differ significantly from what either spouse assumes based on nationality.
Under the 1978 Hague Convention (ratified by France), spouses can choose the law of their common habitual residence or the law of either spouse’s nationality to govern their matrimonial regime. This choice must be made before or at the time of marriage, or formally changed afterwards through a postnuptial agreement.
 
Community of property (communauté de biens) means assets acquired during marriage are jointly owned, typically 50/50. On divorce, both spouses share these community assets. Contrast this with separation of property (séparation de biens), where each spouse owns their own assets independently throughout the marriage.
The UAE applies a separation of property regime by default for non-Muslim couples under the 2022 civil family law. Each spouse owns the assets in their own name. Unlike community of property systems, there is no automatic sharing of assets acquired during the marriage. Only specific claims may arise on divorce.

The higher the asset value, the greater the financial impact of an unfavourable legal regime. Significant assets, including property in multiple countries, company shares and investment portfolios, require precise legal analysis to understand exposure, and targeted contractual arrangements to protect each spouse’s interests.

Key contacts:

Romain Astruc

Managing Partner – Generalist, Advisory & Litigation

Géraldine Heimburger

Partner – Family Law, Notarial & Litigation

David Dutruc-Rosset

Associate – Family, Individuals & Litigation

Other services you might need

Your matrimonial regime affects your wealth structures, succession plan and tax exposure. These services work in close connection.

Asset Protection & Tax Planning for Individuals

Protect your wealth against future claims by combining a sound matrimonial analysis with the right holding structures.

Estate Planning - Wills, Foundations & Trusts

Your matrimonial regime must be aligned with your succession plan. We handle both in a single integrated strategy.

Foundation Setup - incl. Shariah-Compliant Structures

A foundation can provide protection against adverse matrimonial regime outcomes. Timing and structure both matter.

WHAT SET US APART

Why ASTRUC & Co

We combine French civil law with UAE family law expertise – a rare pairing that makes a real difference for international couples.

1.

French-UAE fluency

Most lawyers know one system. We practice both French civil law and UAE family law – and understand how they interact. For internationally mobile couples, that is decisive.

2.

Senior counsel only

Matrimonial analysis carries real financial stakes. Your matter is handled by a partner or senior lawyer, never delegated to a junior. You get the expertise the matter needs.

3.

Practical outcomes

We translate legal analysis into a clear action plan. Whether that means a postnuptial agreement, a revised Will or a foundation structure, we tell you exactly what to do.

More than legal counsel

With you, all the way

Life in the UAE brings extraordinary opportunities — and equally complex legal realities. Whether you’re relocating your family, navigating a divorce across jurisdictions, or structuring an inheritance that spans continents, you deserve a legal partner who understands both the technicalities and the human side of what you’re going through. At ASTRUC & Co, we treat every client’s situation as if it were our own.

From our offices in Dubai to our network spanning Riyadh, Paris, and Luxembourg, we bring senior-level attention to every matter — personal or financial. We believe the best legal advice is honest, clear, and delivered by someone who genuinely cares about the outcome. That’s why our clients stay with us, and why they come back when life presents its next chapter.

Ready to move forward?

Talk to our team about your situation. We’ll walk you through your options and help you move forward with clarity.

One hour consultation

30-minute consultation

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