German Citizens in UAE Legal Disputes?

German and German: What This Means Under UAE Law

If you're asking about "german and german" in a UAE legal context — say, a German national dealing with another German national in a dispute, contract, or family matter here — the short answer is that nationality alone doesn't decide which law applies. UAE courts have their own rules, and they don't always defer to German law just because both parties are German.

Quick answer

When two German nationals interact legally inside the UAE — whether that's a marriage, a contract dispute, an inheritance, or a commercial disagreement — UAE law generally governs the forum and procedure. German substantive law may apply in some narrow situations (personal status, for example), but only if a party actively requests it and proves its content. Don't assume German consulates, German courts, or German law will automatically step in. They usually won't, unless you make it happen through the right channels.

When German law can apply between two Germans in the UAE

UAE Federal Decree-Law No. 41 of 2022 on Civil Personal Status for Non-Muslims, and Federal Law No. 5 of 1985 (the Civil Transactions Law), both allow non-Muslim foreigners to request that the law of their home country govern certain matters — marriage, divorce, inheritance, wills. So yes, two Germans in Dubai can, in principle, ask a UAE court to apply German law to their divorce.

But here's what most clients miss: you have to plead it and prove it. UAE judges don't apply German law on their own initiative. You'll need a certified Arabic translation of the relevant German statute, often with a legal expert's opinion attached. That costs money and time. In my experience, parties who don't prepare this properly end up with UAE law applied by default — which may or may not favour them.

For a German-German commercial contract signed in the UAE, the parties can choose German law as the governing law under Article 19 of the Civil Transactions Law. Choice-of-law clauses are respected, with limits — UAE public policy always wins where it conflicts.^[1]

Personal status: marriage, divorce, inheritance

Two German nationals married in Germany who now live in Abu Dhabi can divorce under Abu Dhabi's Civil Family Court, established under Abu Dhabi Law No. 14 of 2021. That court was built specifically for non-Muslim foreigners and routinely applies the law of the parties' nationality if requested.

Inheritance is trickier. Without a registered will, a UAE court may apply Sharia-based default rules to a deceased German's UAE assets — even if both spouses are German. The fix: register a will. DIFC Wills Service Centre (for assets across the UAE) charges AED 10,000 for a single will and AED 15,000 for mirror wills as of 2024.^[2] Abu Dhabi Judicial Department also registers non-Muslim wills, often cheaper.

Frankly, if you're a German couple with property here and no will, sort that out this month. Not next year.

Commercial disputes between two German parties

Two German companies contracting in the UAE have real options. You can litigate in onshore Dubai or Abu Dhabi courts (Arabic-language, UAE law unless you've chosen otherwise), or you can opt into DIFC Courts or ADGM Courts — both English-language, common-law jurisdictions sitting inside the UAE.

The DIFC Courts accept "opt-in" jurisdiction from parties with no DIFC connection under Article 5(A)(2) of Dubai Law No. 12 of 2004 (as amended).^[3] Two German companies with no Dubai presence can still agree to litigate there. Judgments are enforceable across the UAE and, via the 2009 Hague reciprocity arrangements, in many foreign jurisdictions.

Arbitration is the other route. DIAC (Dubai International Arbitration Centre) and ADGM Arbitration Centre both handle German-German disputes regularly. German is not an official language of either, but tribunals routinely sit in English with German documents translated as needed.

Pick your forum at the contract drafting stage. Switching later is expensive and sometimes impossible.

Practical steps if you're in this situation

Get advice from a UAE-licensed lawyer before you assume anything about how "German and German" disputes work here. The German Consulate in Dubai and the Embassy in Abu Dhabi can notarise documents and provide lists of lawyers, but they don't represent you in UAE proceedings.

If you have a contract being drafted: name the governing law, the forum, the language, and the seat of arbitration. Four lines that save four years of litigation.

If you're already in a dispute: file early, plead foreign law early, and budget for certified translations. Arabic translations from a Ministry of Justice-sworn translator run roughly AED 80–120 per page in 2024.

Need this checked for your situation? Talk to a UAE-licensed lawyer →

Citations

^[1] UAE Federal Law No. 5 of 1985 (Civil Transactions Law), Articles 10–28 on conflict of laws. Official Gazette. ^[2] DIFC Wills Service Centre fee schedule, difcwills.ae (accessed 2024). ^[3] Dubai Law No. 12 of 2004 concerning the Judicial Authority at DIFC, as amended by Dubai Law No. 16 of 2011, Article 5(A). ^[4] Abu Dhabi Law No. 14 of 2021 establishing the Civil Family Court. ^[5] UAE Federal Decree-Law No. 41 of 2022 on Civil Personal Status for Non-Muslims.