Website Last updated:

May 15, 2026

This clarification explains that a Family Foundation lacking a separate legal personality is automatically tax transparent. A foundation with a separate legal personality can apply for this status if it meets the conditions in Article 17 of the Corporate Tax Law. Wholly owned holding companies and SPVs of a transparent foundation can also apply for this status. Single or Multi Family Offices not meeting Article 17 conditions are treated as standard Taxable Persons. Family members are generally not subject to Corporate Tax on income if it qualifies as Personal or Real Estate Investment income.

CTP008

Corporate Tax Public Clarification

Corporate Tax treatment of family wealth management structures

Issue

Article 17 of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses and its amendments ("Corporate Tax Law") and Article 5 of Ministerial Decision No. 261 of 2024, provide for the treatment of family wealth management structures for Corporate Tax purposes.

The purpose of this Public Clarification is to provide clarity on the Corporate Tax implications of family wealth management structures, including a Single Family Office ("SFO") or a Multi Family Office ("MFO").

Summary

A family wealth management structure typically includes the following entities:

a Family Foundation,
a holding company,
a Special Purpose Vehicle ("SPV"),
a SFO or MFO, and
family members.

The Corporate Tax treatment of these entities and the family members is considered in turn below, after which four examples of typical structures are set out.

Detailed Analysis

Family Foundation

A Family Foundation means any foundation, trust or similar entity, whether domestic or foreign, that meets the conditions of Article 17(1) of the Corporate Tax Law. For the avoidance of doubt, "similar entity" means an entity that has a similar legal structure or character to a foundation or trust, and would, therefore, exclude a limited liability company.

A Family Foundation or any family wealth management vehicle that does not have a separate legal personality is automatically considered tax transparent (i.e. not considered a Taxable Person in its own right). Examples include a trust established under Abu Dhabi Global Market ("ADGM") or Dubai International Financial Centre ("DIFC") trust laws.

A Family Foundation that has a separate legal personality can make an application to the FTA to be tax transparent if it meets the conditions of Article 17(1) of the Corporate Tax Law. Examples include foundations established under the ADGM or DIFC foundations laws or trusts established under the UAE Federal Trust Law.

A family wealth management vehicle that has a separate legal personality and does not meet the definition of a Family Foundation or the conditions of Article 17(1) of the Corporate Tax Law is a Taxable Person in its own right., Where such a vehicle is a Free Zone Person ("FZP"), it may benefit from a 0% Corporate Tax rate on Qualifying Income from Qualifying Activities, for example, the holding of shares and other securities for investment purposes.