Tax Readiness for Family Offices and Private Wealth Structures

Created By : Yeeshu Sehgal | UAE Tax Lead

The FTA has now set out clear rules for family wealth structures through Public Clarification CTP008 and the updated Family Foundations Guide.

The message is simple. A UAE family structure can be tax neutral, but only if it is set up correctly, documented properly and kept under review. The family office that runs it is usually taxable in its own right.

What families should know

• Transparency is not automatic. A qualifying Family Foundation must apply under Article 17 of the Corporate Tax Law and confirm its status each year.
• Jointly held SPVs owned by more than one qualifying foundation can now be treated as wholly owned, and so may apply for transparency.
• One break affects the whole chain. If an entity fails the conditions, the entities below it lose transparency too.
• An LLC cannot act as the foundation, although an LLC held under a qualifying foundation may still be transparent.
• The family office is taxable. Its management and advisory fees are subject to Corporate Tax.
• Individuals are not taxed on personal investment or real estate investment income, and business income is taxed only above AED 1 million turnover.

Governance

Most issues arise when the legal structure, decision-making and tax filings drift apart, often after a new SPV is added or shares change hands within the family.

• Keep an up-to-date structure chart showing ownership and the tax status of each entity.
• Document where key decisions are taken, through board and foundation council minutes.
• Support family office fees with a written agreement and an arm’s length benchmark.
• Identify connected persons, including family members acting as directors or officers.

Compliance at a glance

International reporting

• CRS and FATCA: UAE accounts are already reported to the home countries of account holders and controlling persons.
• Crypto assets: the UAE has committed to the OECD crypto reporting framework, with first exchanges in 2028.
• Beneficial ownership: UBO registers should reflect any restructuring, gift or succession event.
• Pillar Two: relevant only to groups with revenue of EUR 750 million or more.
• Home country: UAE transparency does not settle the position in the UK or elsewhere. UK-connected families should also review the transfer of assets abroad, CFC and inheritance tax rules.

Quick readiness check

Before the next tax period begins, ask:

• Is the tax status of every entity in the structure confirmed and recorded?
• Have transparency applications and annual confirmations been filed?
• Is the family office fee arrangement documented and supported?
• Do UBO registers, CRS self-certifications and bank records tell the same story?
• Has each family member’s home-country position been reviewed?

How AKM Global can help

At AKM Global, we assist families, founders and family offices with structure reviews, transparency applications, Corporate Tax and transfer pricing compliance, and international reporting, including cross-border advice for families with links to the UK.

Get in touch with AKM Global to review your family structure ahead of the next tax period.