Inheritance & wills, country by country

Sharia courts (Mahakim) apply classical Sunni faraid directly; the General Court issues the inheritance deed (Sak Hasr al-Irth). No separate civil inheritance code applies to Muslim citizens.

For Muslim citizens, the Federal Personal Status Law (Law No. 28/2005, amended) applies classical Sunni faraid. Since 2020 (Federal Decree-Law 5/2020 and 41/2022), non-Muslims and Muslim expats may opt for the law of their nationality via a registered will.

The Muslim Personal Law (Shariat) Application Act 1962 applies classical Sunni faraid to Muslim citizens. The Succession Act 1925 governs procedural aspects (succession certificates, letters of administration).

Muslim Personal Law (Shariat) Application Act 1937 (as continued by the Constitution of Bangladesh) applies classical Sunni Hanafi faraid to all Bangladeshi Muslims (~91% of the population). The Muslim Family Laws Ordinance 1961 (MFLO) introduced statutory Wajib Wasiyyah for orphaned grandchildren (Section 4) — one of only 3 jurisdictions worldwide with this codified override. Non-Muslims are governed by the Succession Act 1925.

Faraid is administered by State Syariah Courts under Federal Constitution List II (Ninth Schedule); each of the 13 states + 3 federal territories has its own Islamic-inheritance enactment (e.g., Selangor Islamic Family Law Enactment 2003). Civil High Courts handle non-Muslims under the Distribution Act 1958. Cases involving both Muslim + non-Muslim heirs may face jurisdictional deadlocks between Syariah and civil courts (Indira Gandhi v Pengarah Jabatan 2018 FC).

Compilation of Islamic Law (Kompilasi Hukum Islam, 1991) governs Muslim inheritance through Religious Courts (Pengadilan Agama). It follows Sunni faraid with notable modifications: equal shares for sons/daughters is permitted by mutual consent (Article 183 KHI), and the Wajib Wasiyyah is recognised for orphaned grandchildren.

Turkey is a strictly secular republic — the Civil Code (Türk Medeni Kanunu, 2001) governs all inheritance regardless of religion. Sharia faraid is NOT a recognised legal framework.

Testator has full freedom of disposition (England & Wales / Northern Ireland — Inheritance Act 1975 allows certain dependants to claim). Scotland retains legal rights for spouse and children.

Probate law varies by state. Most states allow full testamentary freedom subject to spousal elective-share statutes (typically 1/3 to 1/2 of the augmented estate).

Muslim Personal Law (Shariat) Application Act 1937 applies classical Sunni Hanafi faraid (and Jaʿfari for Shia Muslims — Ithna Ashari, Ismaili) to Indian Muslims (~14% of population). The Indian Succession Act 1925 governs civil-procedure elements (probate, letters of administration). Personal-law codification is politically contested; the Uniform Civil Code proposal in Uttarakhand (2024) partially altered testamentary rules in that state.

Strict civil-law forced-heirship (réserve héréditaire) — descendants are entitled to a reserved portion (1/2 if 1 child, 2/3 if 2, 3/4 if 3+). Only the disposable portion (quotité disponible) can be freely bequeathed.

Civil Code of the Russian Federation (Part III, 2002, arts. 1110-1185) governs all inheritance. Sharia faraid is NOT a recognised legal framework. Forced-heirship (обязательная доля): minor children, disabled parents/spouse and disabled dependants are entitled to no less than half of what they would have received intestate. The republics of Tatarstan, Bashkortostan, Chechnya, Dagestan and Ingushetia have Muslim-majority populations but the federal Civil Code binds all.

Civil Code of Kazakhstan (1999, arts. 1038-1084) governs inheritance for all citizens. Sharia faraid is not part of state law — Kazakhstan is a strictly secular republic. Forced-heirship for minor children, disabled descendants/ascendants/spouse and dependants — minimum half of intestate share (art. 1069). The country is majority Muslim (~70%) but the Constitution binds all secular.

Civil Code (Section VI, arts. 1113-1160) governs all inheritance under a secular civil framework. Forced-heirship for minor and disabled heirs (≥2/3 of intestate share, art. 1141). The Family Code protects spousal rights and joint marital property (rejoinder to inheritance mass). Sharia has no statutory effect — Muslim testators achieve Islamic distribution via a compliant will + inter vivos hibah (gifts).

Civil Code (arts. 1118-1170) governs all inheritance; forced-heirship for minor and disabled heirs at ½ intestate share (art. 1149). Sharia has no statutory effect; faraid achieved via compliant will + inter vivos hibah.

Civil Code (arts. 1141-1194) governs all inheritance; classical civil-law forced-heirship applies. Sharia has no statutory effect; strong state secularism actively restricts overt religious testamentary language.

Civil Code (1999, arts. 1133-1275) governs all inheritance under a secular civil framework. Forced-heirship: minor or disabled heirs receive at least half of their intestate share regardless of any will (art. 1193). Sharia has no statutory effect; faraid via compliant will + inter vivos hibah.

Civil Code (1998, arts. 1128-1183) governs all inheritance; civil-law forced-heirship applies. Sharia has no statutory effect; state secularism strongly enforced.

The Turkish Republic of Northern Cyprus (KKTC) — recognised only by Turkey — applies the KKTC Inheritance Law (Miras Yasası) alongside the KKTC Civil Code, closely aligned with Turkey. Strictly secular framework with statutory reserve (saklı pay); Sharia faraid is NOT a recognised legal framework.

Law No. 77/1943 (inheritance) + Law No. 71/1946 (wasiyyah) codify classical Sunni (Hanafi-default) faraid for Muslims. Egypt is one of the few jurisdictions that applies the statutory Wajib Wasiyyah (Law 71/1946 art. 76) — orphaned grandchildren of a predeceased child inherit through a mandatory bequest up to 1/3.

The Mudawana (Family Code, Law 70-03 of 2004) governs personal status; inheritance follows the Maliki school. Wajib Wasiyyah applies to orphaned grandchildren (art. 369-372).

Family Code (Law 84-11 of 9 June 1984, as amended by Ord. 05-02 of 2005) applies classical Sunni Maliki faraid to all Muslim citizens (~99% of population). Statutory Wajib Wasiyyah (arts. 169-172) protects orphaned grandchildren of a predeceased child up to 1/3 of the estate. The Civil Code (Ord. 75-58) applies to non-Muslim residents.

Code of Personal Status (CSP, Décret du 13 août 1956, extensively reformed) — Tunisia is unique in the Muslim world for its abolition of polygamy (1956) and extensive rights-based reforms. The classical faraid framework remains the legal default in 2026; a 2018 government proposal for equal daughter shares was tabled but not enacted. Wajib Wasiyyah applies (CSP art. 191 bis) for orphaned grandchildren.

Law No. 10/1984 (personal status) applies Maliki faraid to all Muslim citizens; the Civil Code (Law 87/1953) covers procedural matters. Statutory Wajib Wasiyyah recognised for orphaned grandchildren of a predeceased child (up to 1/3).

Personal Status Law of Muslims 1991 (Qanun al-Ahwal al-Shakhsiyya lil-Muslimin) applies classical Sunni faraid (Maliki-dominant; Hanafi for some procedural matters). Zakat is state-collected under the 2001 Zakat Act. Non-Muslims are governed by the Non-Muslim Personal Status Law 1926.

Personal Status Law No. 188/1959 (as amended, Law 21/1978) provides classical Sunni or Jaʿfari (Shia) faraid based on the deceased’s madhhab. Most Iraqi-Muslim inheritance proceeds under Jaʿfari rules — substantially different from Sunni shares for daughters with no son (Jaʿfari daughters take the full estate; Sunni residue goes to distant agnates).

Sharia Courts Law and Personal Status Law No. 36/2010 (successor to Law 61/1976) apply classical Sunni (Hanafi-default) faraid to all Muslim citizens; Christian communities have their own confessional courts. Statutory Wajib Wasiyyah codified for orphaned grandchildren under Art. 279.

For Sunni Muslims: classical Sunni Hanafi faraid under Sunni Sharia Court jurisdiction (Law 177/2011). For Shia Muslims: Jaʿfari faraid under separate Jaʿfari Sharia Courts. Druze have their own confessional code. Non-Muslim communities each have their own confessional code; the 1959 Law of Inheritance for Non-Muhammadans applies civil rules.

Personal Status Law No. 59/1953 (as amended by Law 34/1975 and Law 4/2019) applies classical Sunni (Hanafi-default) faraid to all Muslim citizens; Christian and Druze communities have their own codes. Statutory Wajib Wasiyyah recognised for orphaned grandchildren.

Personal Status Law 61/1976 (West Bank, based on Jordanian Law) and Family Rights Law 303/1954 (Gaza, based on Egyptian Law) both apply Sunni Hanafi faraid. Wajib Wasiyyah recognised for orphaned grandchildren.

Personal Status Law 20/1992 (as amended) applies classical faraid: Sunni Shafiʿi in the south and Tihama regions; Zaydi (Shia) in the northern highlands (Sana‘a, Sa‘dah). Zakat is collected as a statutory obligation under Law 2/1999.

Personal Status Law 51/1984 applies classical Sunni faraid (Maliki-dominant for the personal-status codification, Hanafi as default residual). Shia Kuwaitis apply Jaʿfari faraid via the Jaʿfari Court. Wajib Wasiyyah recognised for orphaned grandchildren.

Family Law No. 22/2006 applies classical Sunni faraid (Hanbali is the state madhhab and default; other Sunni madhhabs applied on request). Statutory Wajib Wasiyyah for orphaned grandchildren recognised.

Sunni Family Law 19/2009 applies classical Sunni faraid (Maliki-default) to Sunni citizens; Jaʿfari Family Law 19/2017 applies Jaʿfari faraid to Shia citizens (roughly 60-70% of the population).

Personal Status Law 32/1997 applies classical faraid: Ibadi (the state madhhab) for the majority; Sunni Shafiʿi/Maliki and Jaʿfari for the respective minority communities based on deceased declaration. Ibadi faraid differs from Sunni in a few residuary rules (e.g. treatment of the paternal grandmother).

Personal Status Code (Ord. 2001-052) applies Maliki faraid for all Muslim citizens (98% of the population); the state officially recognises Maliki jurisprudence as the default source of personal-status law. Wajib Wasiyyah recognised for orphaned grandchildren.

Code de la Famille 1972 (Arts. 571-573) allows Muslim citizens to opt for Islamic Maliki faraid via a witnessed declaration; without such declaration, civil intestacy (equal shares) applies. The declaration can be included in the will itself.

Code des Personnes et de la Famille 2011 (Arts. 751-756) — Muslim citizens may opt for Islamic Maliki faraid via written declaration; without such declaration, civil intestacy applies with equal per-capita shares.

Civil Code applies by default; Muslim citizens (98% of the population) may opt for Maliki faraid via written declaration registered with the notaire. The Constitutional Court has upheld the primacy of civil intestacy absent such declaration (Arrêt 2015).

Code des Personnes et de la Famille 1989 (Arts. 736-745) applies civil intestacy by default; Muslim citizens (~63% of population) may opt for Maliki faraid via a written declaration filed with the notaire and the état civil.

Civil Code (Loi 64-379, revised by Loi 2019-573) applies to all citizens; religious-based personal-status declarations recognised for Muslim citizens (~43% of population) via option in the wasiyyah.

Civil and customary plural system under Code Civil + Ordonnance 03/INT/SUR of 1961 on customary law; Muslim citizens (~55% of population) may opt for Maliki faraid via written declaration.

Civil Code (Napoleonic legacy) applies by default in Francophone regions; Common Law inheritance rules apply in the two Anglophone regions (NW, SW). Muslims (~24% of population, concentrated in the north) may opt for Maliki faraid via written declaration registered with a notaire.

Code Civil (Loi L/2019/010) applies civil intestacy by default; Muslim citizens (~89% of population) may opt for Maliki faraid via written declaration registered with a notaire.

Code des Personnes et de la Famille 2004 (Arts. 630-654) applies civil intestacy by default; religious and customary personal-status declarations recognised. Muslim citizens (~24% of population, concentrated in the north) may opt for Maliki faraid via written declaration.

Family Code (Loi 05-008/AU of 2005) applies Shafiʿi faraid for Muslim citizens (99% of the population); the state officially recognises Shafiʿi jurisprudence as the source of personal-status law.

Family Code (Loi 152/AN/02/4ème L, 2002) applies Shafiʿi faraid for Muslim citizens (94% of the population); civil intestacy applies for non-Muslim residents. Statutory Wajib Wasiyyah recognised for orphaned grandchildren.

Provincial succession laws apply (e.g., Succession Law Reform Act in Ontario, Wills Act provincial variants). Sharia faraid is not civilly recognised — Muslims must use a civilly-valid will that mirrors faraid distributions.

Belgian Civil Code (Code civil / Burgerlijk Wetboek) Book III Title I applies forced-heirship (réserve héréditaire / voorbehouden erfdeel) — since the 2018 reform, descendants collectively reserve 1/2 of the estate regardless of the number of children, and surviving spouse retains a usufruct (vruchtgebruik) over the family home. Sharia faraid not directly recognised. EU Succession Regulation 650/2012 election available.

Dual system. In the 12 northern Sharia-implementing states (Zamfara → Borno) Muslims fall under Sharia Penal & Personal Status codes administered by Sharia Courts of Appeal — classical Maliki faraid is applied directly. In the southern states the Wills Act 1958 / Wills Law of each state and Yoruba/Igbo customary law apply; Muslims must opt in to Islamic distribution via a registered will or sworn declaration.

The Civil Code of Iran (Books IX–X, 1928 + amendments) codifies Jaʿari (Twelver Shia) faraid. Sunni Muslims (Kurdish, Baluch, Turkmen) may petition the court to apply their own madhhab under Art. 12 of the Constitution.

The Civil Code of Afghanistan 1977 (still in force in substance) codifies classical Sunni Hanafi faraid for the Sunni majority; Shia (mostly Hazara) follow Jaʿari faraid under the Shia Personal Status Law 2009. Tribal jirga adjudication remains common in rural areas.

The Religious Council Act (Majlis Ugama Islam, Adat Istiadat dan Mahkamah Kadi) Cap. 77 applies classical Sunni Shafi‘i faraid for Muslims via the Syariah Courts. For estate administration the Probate and Administration Act Cap. 11 governs procedure. Non-Muslim residents fall under the Civil Code.

Dual system. The Law of Succession Act (Cap. 160) is the default for all Kenyans. Section 2(3) exempts Muslims from the Act for estates devolving on or after 1 January 1991 — Muslim estates are administered under classical Sunni Shafi‘i (coastal communities) or Hanafi/Maliki (immigrant communities) faraid through the Kadhi’s Courts (established under Art. 170 of the 2010 Constitution).

Multi-system jurisdiction. Indian Succession Act 1865 (statutory), Customary Law Declaration Order 1963 (tribal), and Islamic Law (recognised under the Judicature and Application of Laws Act Cap. 358) co-exist. Muslims have the right to elect Islamic faraid via a recorded declaration; coastal Tanzania (Tanga, Dar es Salaam, Zanzibar) overwhelmingly follows Shafi‘i fiqh.

The Succession Act (Cap. 162) is the statutory framework. Muslims are entitled to apply classical Sunni faraid (predominantly Maliki) through the Qadhis’ Courts established under the Uganda Muslim Supreme Council, but these courts have limited statutory recognition — most Muslim probate is processed in the Magistrate / High Court applying faraid by election in the will.

The Civil Code 1960 (Book III) is the default. Federal Proclamation 188/1999 establishes Federal Sharia Courts for Muslim personal-status matters (including inheritance) where ALL parties consent in writing to Sharia jurisdiction. Without that consent the Civil Code applies. Most Ethiopian Muslims follow Shafi‘i fiqh (Harar, Wollo, Bale, Arsi).

Classical Sunni Shafi‘i faraid is the de-facto rule across federal Somalia (Civil Code 1973 Art. 173 + Family Law). Puntland and Somaliland operate parallel court systems with Islamic-law foundations. Customary "Xeer" law applies in some pastoral disputes but generally yields to faraid for property division.

Plural-law system. Muslim Marriage and Divorce Act No. 13 of 1951 + Muslim Intestate Succession Ordinance Cap. 64 apply classical Sunni Shafi‘i faraid for Sri Lankan Muslims (~10% of population, concentrated in Eastern Province + Colombo). General population governed by the Roman-Dutch–based civil law.

Presidential Decree No. 1083 (Code of Muslim Personal Laws of the Philippines, 1977) codifies classical Sunni Shafi‘i faraid for Muslim Filipinos (≈10% — Bangsamoro, Maranao, Tausug, Maguindanao). Administered through the Sharia District Courts and Sharia Circuit Courts under the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM). Non-Muslim Filipinos governed by the Civil Code of the Philippines.

Civil Code of the People’s Republic of China (2021, Book VI) is the sole legal framework. Sharia faraid has no formal recognition. Muslim minorities (Hui ~10.6M, Uyghur ~12M, Kazakh, Dongxiang, Salar) traditionally distribute estates through faraid within the family but the legal title transfer follows the Civil Code’s statutory rules.

Wills Act 7 of 1953 + Intestate Succession Act 81 of 1987 govern all South Africans. Section 2(2)(g) of the Wills Act explicitly recognises a Muslim’s freedom to distribute via wasiyyah. The 2017 Constitutional Court ruling (Hassam v Jacobs) confirmed Muslim marriages (including polygynous) qualify for estate purposes. United Ulama Council of SA + Muslim Judicial Council issue faraid rulings.

Civil and Commercial Code Book VI applies to all Thais (default statutory shares). Muslims in the 4 southern provinces (Pattani, Yala, Narathiwat, Satun) may elect Islamic faraid under the Application of Islamic Law in the Provinces of Pattani, Narathiwat, Yala and Satun Act B.E. 2489 (1946) — administered through the Provincial Islamic Council (Majlis al-ʻAlam al-Islami).

Muslim Personal Law (Shariat) Application Act 1937 (inherited from British India) applies classical Sunni Hanafi faraid for Burmese Muslims (Rohingya, Bama Muslims, Kaman, Indian-origin Muslims). General Burmese law (1898 Statutes) for non-Muslims.

Constitution Art. 10(a) declares Islam the state religion and Sharia the source of law. Family Act 4/2000 + Maldivian Penal Code 2014 apply classical Sunni Shafi‘i faraid for all citizens (Maldives is a 100% Muslim state by law).

German Civil Code (Bürgerliches Gesetzbuch — BGB Book V) applies forced-heirship (Pflichtteil) to children, spouse and parents. Sharia faraid is NOT recognised; Muslims must approximate it via a will respecting the Pflichtteil. EU Succession Regulation 650/2012 allows election of nationality's law.

Italian Civil Code (Codice Civile) Book II imposes Legittima (forced-heirship) — children, spouse and ascendants reserve a substantial portion of the estate. Sharia faraid not recognised. EU Succession Regulation 650/2012 allows election of nationality's law.

Spanish Civil Code (Código Civil) Book III imposes legítima — children reserve 2/3 of the estate (1/3 strict + 1/3 mejora). Several autonomous communities (Cataluña, Aragón, Basque, Navarra, Galicia) have their own foral systems with different reserves. EU Succession Regulation 650/2012 election available.

Dutch Civil Code (Burgerlijk Wetboek Book 4) applies legitieme portie — children reserved 1/2 of their statutory share. Sharia faraid not recognised. EU Succession Regulation 650/2012 election available.

Swiss Civil Code (Zivilgesetzbuch — Schweizerisches ZGB) Art. 470 applies Pflichtteil to descendants (3/4 of statutory share) and surviving spouse (1/2). Sharia faraid not recognised. Foreign-domiciled Muslims may elect their nationality's law (Federal IPL Act Art. 87).

Austrian Civil Code (ABGB §§ 727–824) applies Pflichtteil to descendants and surviving spouse — 1/2 of statutory share. Islam is a recognised religion (Islamgesetz 1912 + reform 2015); the Islamische Glaubensgemeinschaft (IGGÖ) provides faraid guidance. Sharia not directly enforced by civil courts.

Inheritance Code (Ärvdabalken 1958:637) governs all Swedish residents. Laglott (forced-heirship) reserves 1/2 of the estate to children. Sharia not recognised. EU Succession Regulation 650/2012 election available.

Danish Inheritance Act (Arveloven, Lov nr. 515/2007 as amended) reserves tvangsarv (forced-heirship) — descendants + spouse each entitled to 1/4 of the statutory intestate share (a relatively low reserve by European standards). EU Succession Regulation 650/2012 election available for foreign-nationals.

Inheritance Act (Arveloven 2019) reserves pliktdel — descendants entitled to 2/3 of the estate (capped at NOK 15× the basic amount per child). EU Succession Regulation does NOT apply (Norway is not an EU member); 1989 Hague Convention applies to limited jurisdictions.

Albanian Civil Code (Ligj 7850/1994, Book III) governs all Albanians. Forced-heirship (legjitima) reserves descendants + spouse + parents at 1/2 of their statutory share (Art. 379-380). The Albanian Muslim Community (Komuniteti Mysliman i Shqipërisë, KMSH) provides faraid guidance for the ~60% Muslim population; civil courts have ultimate jurisdiction and there is NO Sharia court structure.

Inheritance Law of the Federation of BiH 80/2014 (Federacija) + Republika Srpska Inheritance Law 1/2009 govern separately by entity. Forced-heirship (nužni dio) reserves descendants + spouse + parents at ~1/2 of statutory share. The Islamic Community of BiH (Islamska Zajednica u BiH) is the constitutionally recognised body providing faraid guidance for the ~50% Muslim population.

Inheritance Law of Kosovo (Law No. 2004/26, as amended by Law No. 06/L-006) governs all Kosovars. Forced-heirship (pjesa e domosdoshme) reserves descendants + surviving spouse at 1/2 of statutory share. The Islamic Community of Kosovo (Bashkësia Islame e Kosovës) provides faraid guidance for the ~95% Muslim population; civil courts have ultimate jurisdiction and there is NO Sharia court structure.

Inheritance Law (Закон за наследувањето, Služ. vesnik 47/1996 as amended) governs all North Macedonians. Forced-heirship (нужен дел) reserves descendants + spouse + parents at 1/2 (descendants) or 1/3 (spouse/parents) of statutory share. The Islamic Religious Community of North Macedonia (Исламска верска заедница, IVZ) provides faraid guidance for the ~33% Muslim population (mainly ethnic Albanians + Turks + Torbeš).

Inheritance Law (Zakon o nasljeđivanju, 74/2008 as amended) governs all Montenegrins. Forced-heirship (nužni dio) reserves descendants + spouse + parents at 1/2 of statutory share. The Islamic Community of Montenegro (Islamska Zajednica u Crnoj Gori, IZCG) provides faraid guidance for the ~20% Muslim population (Bosniaks in Sandžak-Montenegro + Albanians in Ulcinj/Tuzi).

Inheritance Law of Serbia (Zakon o nasleđivanju 46/1995, as amended by 101/2003 and 6/2015) governs all Serbians. Forced-heirship (nužni deo) reserves descendants + spouse + parents at 1/2 of statutory share. The Islamic Community of Serbia (Islamska Zajednica Srbije) provides faraid guidance for the ~3% Muslim population (mainly in Sandžak — Novi Pazar, Tutin, Sjenica).

Inheritance Act (Zakon o nasljeđivanju, NN 48/2003 as amended) governs all Croatians. Forced-heirship (nužni dio) reserves descendants + spouse at 1/2 of statutory share; parents get 1/3 only if dependent. The Islamic Community of Croatia (Islamska Zajednica u Hrvatskoj, MIZ) provides faraid guidance for the ~1.5% Muslim population. Croatia is an EU member — EU Succession Regulation 650/2012 election available.

Inheritance Act of Slovenia (Zakon o dedovanju, UL SRS 15/1976 as amended) governs all Slovenians. Forced-heirship (nujni delež) reserves descendants + spouse + dependent parents at 1/2 of statutory share. The Islamic Community of Slovenia (Islamska skupnost) provides faraid guidance for the ~2% Muslim population. EU Succession Regulation 650/2012 election available.

Inheritance Law of Bulgaria (Закон за наследството, ДВ 22/1949 as amended) governs all Bulgarians. Forced-heirship (запазена част) reserves descendants + spouse + dependent parents at 1/2 (one child) to 2/3 (three or more children) of the estate. The Chief Mufti's Office of Bulgaria (Главно мюфтийство) provides faraid guidance for the ~10% Muslim population (mainly Turks, Pomaks, Roma Muslims). Bulgaria is an EU member — EU Succession Regulation 650/2012 election available.

The Polish Civil Code (Kodeks cywilny, Book IV) governs inheritance for everyone including the ~30,000-strong Muslim community (Polish Tatars in Kruszyniany/Bohoniki + growing Ukrainian, Turkish, Chechen and MENA expat populations in Warsaw, Kraków and Wrocław). Poland is an EU member — Regulation (EU) 650/2012 lets Muslim expats elect the law of their nationality via a written declaration in their will.

The Portuguese Civil Code (Código Civil, Book V) governs succession. Muslim community ~65,000 (Guinea-Bissau, Mozambique, Bangladesh, Pakistan, Morocco heritage — concentrated in Lisbon, Porto, Odivelas). Portugal is an EU member and Regulation 650/2012 allows expats to elect the law of their nationality via will.

The Succession Act 1965 governs Irish estates. Muslim community ~80,000 (largely Pakistani, Nigerian, Somali, Malaysian, Egyptian professionals concentrated in Dublin, Cork, Galway). Ireland has opted OUT of the EU Succession Regulation 650/2012, so Irish rules apply to any property situated in Ireland regardless of nationality.

The Finnish Code of Inheritance (Perintökaari, 1965) applies to all residents. Muslim community ~100,000 (Somalis, Tatars — the 200-year-old Finnish Tatar community are indigenous Muslims — plus Iraqis, Kurds, Turks in Helsinki, Tampere, Turku). Finland is an EU member; Regulation 650/2012 election available.

The Greek Civil Code (Αστικός Κώδικας, Book VI) governs the general population. HOWEVER, Greek Muslims of Western Thrace (~120,000, Turkish/Pomak/Roma) have historically been governed by SHARIA COURTS via the Mufti of Xanthi, Komotini, Didymoteicho under the Treaty of Lausanne (1923) and Law 1920/1991. Since Law 4511/2018 sharia jurisdiction is OPTIONAL — Muslims must expressly elect it, otherwise Civil Code applies.

The Civil Code of 2014 (Občanský zákoník, Book III) governs succession. Muslim community ~20,000 (mostly Arab, Turkish, Bosnian, Chechen professionals in Prague and Brno; strong tech and academic presence). Czech Republic is an EU member — Regulation 650/2012 election available for expats.

The Napoleonic Civil Code (Book III) governs Luxembourg estates. Muslim community ~15,000 (mostly Bosnian, Kosovar, Moroccan, Algerian, Turkish + growing MENA fintech professionals). Luxembourg is an EU member and Regulation 650/2012 election is widely used given Luxembourg's expat-heavy population.

Each Australian state and territory has its own Succession Act (NSW Succession Act 2006, VIC Wills Act 1997, QLD Succession Act 1981, etc.), all following Anglo-Saxon common-law tradition. Muslim community ~900,000 (largest in Sydney and Melbourne; Lebanese, Turkish, Afghan, Indonesian, Somali, South Asian heritage). No sharia jurisdiction — a Muslim will must satisfy state formality rules and then be interpreted per its own faraid clauses.

The Wills Act 2007 and Administration Act 1969 govern New Zealand estates. Muslim community ~60,000 (Fijian-Indian, Somali, Afghan, Indonesian, MENA heritage — concentrated in Auckland, Christchurch, Hamilton). Common-law tradition; no sharia jurisdiction.

Singapore operates a DUAL system: the Administration of Muslim Law Act (AMLA) 1966 gives the Syariah Court exclusive jurisdiction over Muslim inheritance for Muslim citizens/residents; non-Muslims fall under the Wills Act and Intestate Succession Act. Muslim community ~700,000 (~15% of population — Malay, Indian-Muslim, Arab heritage). MUIS (Islamic Religious Council of Singapore) issues the Inheritance Certificate.

The Japanese Civil Code (民法, Book V) governs succession. Muslim community ~230,000 (Indonesian, Pakistani, Bangladeshi, Turkish, Malaysian, Iranian, Arab professionals + students; concentrated in Tokyo, Osaka, Nagoya). No sharia jurisdiction; Japanese law applies to all Japan-situated property regardless of nationality (though foreigners can choose the law of their nationality under the Application of Laws Act, Article 36).

The Brazilian Civil Code of 2002 (Código Civil, Book V) governs succession. Muslim community ~200,000 (large Lebanese, Syrian, Palestinian diaspora from 1880s onwards + growing Egyptian and West African converts — concentrated in São Paulo, Foz do Iguaçu, Rio de Janeiro). Common-law does not apply; Brazil uses continental civil-law forced-heirship rules.