London law firms are reporting a surge in instructions from wealthy families across the Gulf Cooperation Council (GCC) states seeking to draft what practitioners call ‘sharia-lite’ wills. These estate plans aim to distribute assets more equally between sons and daughters, moving away from traditional Islamic inheritance rules that typically grant male heirs a double portion.
The trend, confirmed by multiple private client partners at London-based firms, reflects a broader generational shift among ultra-high-net-worth families in the Middle East. Clients are increasingly concerned with ensuring financial parity among all children, regardless of gender, while still grounding their estate plans in a framework they consider broadly consistent with their faith.
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The mechanics of a ‘sharia-lite’ strategy
Traditional Islamic inheritance law, or faraid, sets out fixed shares for heirs. A son, for example, typically receives twice the share of a daughter. For many modern families, particularly those with daughters who are equally involved in family businesses or who have received a Western education, this rigid structure no longer reflects their wishes.
London solicitors say they are structuring these plans through a combination of English will provisions and lifetime gifts. By transferring assets into trusts during the testator’s lifetime, or by using specific bequests that are permissible under Sharia, families can effectively rebalance the final distribution. The goal is to create a plan that is defensible in both English probate court and, if challenged, in a Sharia court.
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“The demand is very real,” said a partner at a leading London private client firm who spoke on condition of anonymity due to the sensitivity of client matters. “These are families who want to treat their children equally. They see it as a matter of fairness and family harmony. They come to London because English law gives them the flexibility to achieve that while still feeling connected to their religious principles.”
Why London? Jurisdiction and expertise
London’s position as a premier global wealth management hub is central to this trend. The UK legal system has centuries of experience with trusts and estates, and English courts are widely seen as stable, predictable, and protective of private property rights. For families with assets spread across multiple jurisdictions—including UK property, Swiss bank accounts, and international investment portfolios—having a single, solid will governed by English law simplifies succession planning.
The UK also does not impose inheritance tax on non-domiciled individuals for their non-UK assets, which is a significant draw for international clients. Furthermore, the legal profession in London has developed deep expertise in cross-border Islamic estate planning, combining knowledge of English trust law with an understanding of Sharia principles.
This is not an entirely new phenomenon, but solicitors report that the volume of inquiries has increased markedly since the pandemic. The post-COVID period has prompted many wealthy individuals to review their estate plans, and the rising number of second- and third-generation family members educated in the West has accelerated the desire for more egalitarian distribution models.
Implications for families and the wider market
For the families involved, the shift is deeply personal. Disputes over inheritance can fracture family relationships and damage business empires. A will that is seen as fair by all beneficiaries—and that is legally strong—can prevent years of costly litigation.
The trend also has broader implications for the wealth management industry. Law firms that can demonstrate genuine expertise in both English trust law and Islamic finance are gaining a competitive edge. Some firms have established dedicated Islamic estate planning teams. Others are training their private client lawyers in the nuances of Sharia succession.
Critics, including some conservative Islamic scholars, argue that the ‘sharia-lite’ approach risks undermining the divine injunctions of faraid. They contend that the fixed shares are not merely cultural but are mandated by the Quran. Proponents, however, argue that the use of permissible legal structures like gifts and trusts during one’s lifetime is a legitimate form of planning that does not violate core principles.
For now, the market is responding to clear client demand. As one London-based wealth advisor put it, “The families driving this are sophisticated global citizens. They want a plan that works for their family, their faith, and their finances. London is the place where they can get all three.”
