Foreign direct investment (FDI) is a key driver of economic diversification and competitiveness in Gulf economies, making its legal regulation increasingly significant. This study is motivated by the UAE’s legislative shift following Federal Decree-Law No. 26 of 2020, which repealed the Foreign Direct Investment Law and integrated FDI regulation into the Commercial Companies Law. Despite these reforms, a gap remains in the literature regarding the adequacy and clarity of investor protection under a unified legal framework, particularly when compared with jurisdictions maintaining independent investment legislation such as Kuwait. The study aims to analyze and compare the legal rules, guarantees, and incentives governing FDI in the UAE and Kuwait. Adopting a comparative analytical legal methodology, the research examines statutory provisions, executive regulations, and investment treaties. The findings indicate that the UAE has liberalized foreign ownership but relies on dispersed guarantees, while Kuwait adopts a more coherent statutory framework. Comparatively, the Kuwaiti model offers greater legal certainty, enhancing its effectiveness in attracting foreign direct investment. his study contributes to comparative investment law scholarship by identifying legislative strengths and gaps in both systems and by providing policy-oriented insights aimed at enhancing investor protection and regulatory certainty in the UAE.
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