When deals, contracts, or family matters cross borders, questions always come up: Which country’s laws apply? Can I choose the rules I want? What happens if there’s a dispute in the UAE?

At RH & HALE Lawyers in Dubai, we help individuals and businesses resolve these “conflicts of laws” on a daily basis. We advise and assist you to understand your options, safeguard your rights and prevent costly surprises under UAE law. Whether you need to sign an international contract, deal with property in another country or resolve a family or commercial dispute with foreign elements, our team offers practical and direct solutions.

What Are Conflicts of Laws?

Conflicts of laws (sometimes known as private international law) is the set of rules which resolves three important issues that arise in cases in which multiple countries are involved:

1. Which court has the power to hear the case (jurisdiction)?
2. Which country’s laws the court should use (applicable law or choice of law).
3. Whether a judgment or contract from another country will be recognized and enforced in the UAE.

In other words, it is the process of determining: Whose laws prevail when laws conflict?

This practice is important in the UAE, where not only Dubai but the entire country attracts international investors, families and workers from around the world.

How Conflicts of Laws Work in the UAE ?

The UAE has a modern civil law system. The main rules on conflicts of laws are contained in the new Civil Transactions Law (Federal Decree-Law No. 25 of 2025), which will come into force on 1 June 2026. This replaced the older 1985 Civil Code and brought clearer, more business-friendly updates.

The main changes to the current law are:

• Party Choice is Stronger: You and the other party can clearly choose which country law will apply to your contract – for both form and substance. This decision is respected unless it is against public order, morals, or mandatory UAE rules (like Sharia principles in certain areas).

• No Choice Made? If they do not agree, the law of the country in which the contracting parties have their common domicile shall apply. If their domiciles differ, the law of the country where the main obligation of the contract is to be performed shall apply, unless it is clear from the circumstances that another law is intended to be applied.
• Real Estate and Property: Rights to land and buildings are almost always governed by the law of the country in which the property is situated (the “situs” rule). 
• Public Policy Protection: Even if you opt for foreign law, UAE courts will not apply it if it is in conflict with UAE public order, morality or key mandatory rules.
• Family and personal matters: Marriage, divorce, inheritance and child custody rules are often based on the law of the person’s nationality, with important exceptions and protections under UAE law.

These rules apply onshore in the UAE. Free zones like DIFC and ADGM have their own common-law based systems, which can create additional layers in conflict of laws cases.

Common Situations Where Conflicts of Laws Arise in the UAE

1. International Business Contracts: Choice of law clauses, enforcement of foreign judgments or disputes concerning cross-border trade and supply agreements.
2. Real Estate and Property Investment: Foreign owners buying in Dubai, joint ventures or disputes concerning overseas financing.
3. Employment and Labour Issues: Contracts for international employees, termination or disputes concerning employees from different home countries.
4. Family Law Matters: Divorce, child custody or inheritance, where spouses/heirs belong to different nationalities.
5. Commercial Disputes: Agency agreements, franchising, joint ventures or recovery of cross border debt.
6. Enforcement of foreign judgments or arbitral awards: Recognizing decisions from other countries in UAE courts.

Why You Need Expert Help with Conflicts of Laws?

A mistake here can cost you time, money, an unenforceable contract, and an unenforceable judgement in the UAE. A good choice of law and jurisdiction clause can save you time and money.

RH & HALE Lawyers:

• Review and prepare contracts with strong governing law and jurisdiction clauses that reflect the UAE rules.
• Advise on the most appropriate structure for your circumstances, choosing between UAE law, English law, or another system.
• Represent you in court or arbitration where there are conflicts of law issues.
• Assist with the enforcement (or challenge) of foreign judgments and arbitration awards in the UAE.
• Advise international clients on compliance with onshore UAE law and free zone rules.

Our lawyers are highly experienced in UAE Federal law, Dubai courts, and the new Civil Transactions Law. Let us help you understand the rules confidently so you can move forward with peace of mind.

Real Help for Your Situation

There are no two cases alike. Whether you’re a business owner closing a big deal, an investor protecting your assets or a family facing cross border issues we focus on what matters to you: clear answers, practical options and results that protect your interests under UAE law.
Ready to have your conflicts of laws question answered? 

Contact RH & HALE Lawyers for a consultation. We help you understand the rules with confidence so you can move forward with peace of mind.