The Dubai International Financial Centre (DIFC) was formed in 2004 pursuant to Dubai Law No. 9/2004 on the Dubai International Financial Centre, abrogated by Dubai Law No. 5/2021 on the Dubai International Financial Centre. As such, the DIFC is an independent jurisdiction in the UAE and has its own civil and commercial legal framework, inclusive of financial services regulation and a courts system modelled closely on international standards and principles of common law.

As per DIFC Law No. 3/2004 Law on the Application of Civil and Commercial Laws in the DIFC, DIFC laws can be applied in the DIFC notwithstanding any federal law on civil or commercial matters. Article 8 of DIFC Law No. 3/2004 provides that in the absence of any express provisions, the laws that will be applied will be the laws of any jurisdiction which appears to the court to be the one most closely related to the facts of and the persons concerned in the matter. DIFC Law No. 3/2004 further provides that if it is unclear which laws should apply, the DIFC Courts will apply the law of England and Wales.