In the United Arab Emirates, Family Foundations, asset-holding companies and family offices are increasingly being used to manage, protect and transfer family wealth across generations.
This article examines the Corporate Tax treatment of these structures in light of the guidance issued by the Federal Tax Authority. Particular attention is given to the distinction between personal investment and business activities, the conditions governing the tax-transparent treatment of Family Foundations, and the role of governance and economic substance in mitigating the risk of recharacterisation.
The analysis also considers the principal implications for Italian HNWIs seeking to structure or manage their wealth in the United Arab Emirates.
The article forms part of Tax Atlas UAE, the series curated by Giovanni Siciliano for Middle East News, focusing on the key tax and legal aspects of investing in the United Arab Emirates.