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.

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. 1
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).
3 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.
1 Examples
include foundations established under the ADGM
or DIFC foundations laws or trusts established
under the UAE Federal Trust Law