In an increasingly complex and transparent global environment—characterised by exchange of information, global minimum tax, anti-avoidance rules and cross-border mobility—traditional wealth structures are no longer sufficient on their own. International entrepreneurs and families need tools that are flexible, robust and adaptable over time.
UAE foundations respond precisely to this need. They offer a tailor-made structure that can evolve alongside the client’s personal, business and tax situation—making them one of the most effective solutions currently available for international wealth planning.
UAE foundations can be established in specific free zones such as RAK ICC, ADGM and DIFC. They are independent legal entities, distinct from the founder: once assets are transferred, they are owned by the foundation itself, creating a clear and effective separation between personal wealth and protected assets, and significantly reducing exposure to personal risks and claims.
This does not imply a loss of control, as the founder can define through the Charter/By-laws:
The foundation is managed by a Council, where the founder can also play an active role, including acting as chairman. This ensures that strategic control remains in place, even after the transfer of ownership.
Importantly, the structure is not static. The Charter can generally be amended during the founder’s lifetime, allowing the foundation to adapt to changing circumstances—a critical feature in an international context.
The founder can also be included among the beneficiaries continuing to benefit from the income generated by the underlying assets.
Under UAE Corporate Tax rules, they may qualify as Family Foundations and be treated as fiscally transparent vehicles. This means that:
To achieve this treatment, the structure must be correctly designed. The foundation should act as a holding and wealth management vehicle, not as an operating business, and its activities must remain ancillary to its purpose. When properly structured, this results in a solution that combines tax efficiency with full compliance, aligning with the increasing demands for transparency at a global level.
One of the key strengths of a UAE foundation is its ability to act as a central holding structure, consolidating (i) corporate participations, (ii) real estate, (iii) financial investments and so on into a single vehicle, enhancing governance and streamlining management.
At the same time, the legal separation ensures that these assets are protected from personal exposure, making the structure particularly effective for entrepreneurs operating across multiple jurisdictions. What makes the model especially attractive is the balance it achieves: ownership is transferred, while strategic control is retained.
The founder continues to shape strategy and long-term decisions without direct exposure, retaining influence through their role in the Council, their position as beneficiary, and the ability to amend or even terminate the foundation.
A UAE foundation is not just a holding vehicle—it is also a ready-made succession structure.
Beneficiaries are defined in advance, and distribution rules are embedded directly in the governing documents. This allows wealth to be transferred according to a clear and predetermined framework, without relying on probate procedures or local inheritance laws.
The presence of mechanisms such as the “Designee”—which may be an individual or a legal entity—ensures continuity in all scenarios by acting as a residual beneficiary, guaranteeing that the assets are ultimately transferred in accordance with the founder’s wishes, even if the originally designated beneficiaries are no longer in place. This results in:
A trust remains an exceptional tool—particularly for succession planning, where it allows assets to be bound to a specific purpose with post-mortem effect—whereas a foundation is a legal entity that directly owns and governs assets, providing greater clarity and control.
With a long-standing and well-established track record, Fidinam supports international entrepreneurs, investors and family offices in structuring, protecting and transferring wealth across jurisdictions. Through its global network of offices and trustee companies, the Group delivers integrated solutions, including the establishment and administration of foundations, holding structures and trusts, ensuring full alignment with clients’ strategic, legal and tax objectives.
In an increasingly complex cross-border environment, Fidinam combines recognised expertise with a multidisciplinary approach to provide robust, compliant and sustainable wealth planning solutions.
This article is edited by Iacopo Carraro - Italian Desk, Fidinam Dubai. If you require clarification or wish to request a tax consultancy, please use the form below.