Marriage

Clear legal support for marriage in the UAE, helping you protect your rights, family, assets and future. With senior legal guidance.

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.

  • We analyze your marital history to determine which country’s law governs your assets (e.g., community vs. separation of property).
  • We then provide critical advice on the choice of law for your marriage even many years after the marriage was entered into, a decision that fundamentally impacts your family life, marriage, children and eventually divorce.

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 rate)

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's one of the most important legal steps you can take.

Frequently asked questions

In most countries, particularly EU countries, it depends on your first common residence after the wedding, not where you married even if the civil servant told you otherwise. If you settled abroad, local law applies. This matters enormously for asset division on divorce, and most couples only discover this when it’s too late to plan.
Not automatically. Your first common residence determines the applicable regime. If that was the UAE, separation of property applies, meaning each spouse keeps their own assets. Your French marriage certificate does not override this rule.
 
Yes, in many jurisdictions you can modify your regime through a postnuptial agreement. In the UAE, an Abu Dhabi postnuptial agreement can cover assets located there. Timing and jurisdiction-specific rules vary, so the right advice up front matters.
Strongly recommended. A prenup lets you choose which country’s law governs your assets and clarifies entitlements before any dispute arises. It can prevent years of cross-border litigation if the marriage ends, and it removes uncertainty around assets in multiple jurisdictions.

No. For non-Muslim expatriates, a civil framework applies, not Sharia. Sharia rules only apply when both spouses choose them, or when the husband is from a Muslim-majority country and both parties agree. The default for expat couples is a civil, separation-of-property regime.

Key contacts:

Romain Astruc

Managing Partner – Generalist, Advisory & Litigation

Géraldine Heimburger

Partner – Family Law, Notarial & Litigation

David Dutruc-Rosset

Associate – Family, Individuals & Litigation

Get in touch

Other services you might need

Your matrimonial regime doesn’t sit in isolation – divorce, estate planning and tax exposure are all directly affected by it.

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UAE Wills - DIFC, ADGM & Dubai Court Wills

Ensure your UAE assets pass to the right people, on your terms, without relying on default inheritance rules.
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WHAT SET US APART

Why ASTRUC & Co

We combine French civil law expertise with UAE family law practice – a rare pairing that makes all the difference.

1.

French-UAE fluency

Most family lawyers in the UAE know local law. We also know French civil law and EU private international law – which is precisely what international couples need most.

2.

Senior counsel only

Matrimonial regime analysis carries real financial stakes. Your matter is handled by a qualified partner or senior lawyer – not delegated to a junior.

3.

Practical outcomes

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

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.

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  • Brief on matrimonial regimes and applicable laws
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