TRW & Co · Private wealth and family business
Setting Up a Family Office in the UAE
A family office UAE families set up usually combines a single family office registered in the DIFC or ADGM with foundations and holding companies that own the assets. Serving only one defined family keeps it outside financial services regulation; serving others does not. Tax, succession and residence must be designed together from day one.
Key pointThe office should manage the wealth, not own it: keep assets in a foundation and holding companies, and remember the office company itself is generally taxable on its fees even when the family foundation is transparent.
At a glance
DIFC net asset test
The DIFC Family Arrangements Regulations, in force since 31 January 2023, set a minimum aggregate family net asset value of USD 50 million in the published text.
ADGM privacy option
From 4 September 2024, ADGM single family offices can register as Restricted Scope Companies, keeping owners and directors off the public register.
One family only
Serving one defined family is generally unregulated in the DIFC and ADGM; managing unrelated families' assets usually needs DFSA or FSRA authorisation.
Foundation tax transparency
Article 17 of the Corporate Tax Law lets qualifying family foundations apply to the FTA for transparent treatment; the office company itself remains taxable on fees.
Ownership separate from management
The office employs staff and provides services; a foundation and holding companies should own the portfolio, property and operating businesses.
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Family office UAE: the short answer
Setting up a family office UAE families can rely on means making three decisions in the right order: whether the office will serve one family or several, where it will sit (the DIFC, ADGM, another free zone or the mainland), and which vehicles will actually own the assets beneath it. A single family office that serves only one defined family is generally outside financial services regulation in the DIFC and ADGM, provided it registers under the relevant family office regime. Managing money for unrelated families is a regulated activity.
The office itself is usually a modest company: it employs staff, holds service agreements and runs governance. The wealth sits in separate holding vehicles, commonly a DIFC or ADGM foundation at the top with holding companies below. Corporate tax, residence visas, succession and banking all have to be designed alongside the legal structure, not after it.
This guide explains the 2026 position on both financial centres, how to choose between them, the tax design that keeps a family structure efficient, and the mistakes we see most often. For our full service description, see the practice page on family offices in the UAE.
What a family office does, and what it is not
A family office manages the investments, property, philanthropy, administration and succession arrangements of a family. In practice the term covers a wide range: from a finance director and an assistant running a holding company, to a full investment platform with its own investment committee, risk function and custodian relationships.
The legal point is that the family office is the management layer. It should not normally be the entity that owns the family's portfolio, real estate or operating businesses. Keeping ownership and management separate protects assets from the office's own commercial risks, makes the tax analysis cleaner and lets the family change service providers without moving assets.
A family office is also not a substitute for personal planning. Assets left in individual names still pass under the succession rules that apply to that person. Wills, foundation documents and the family's governance charter must point in the same direction.
The legal framework for a family office UAE structure
DIFC: the Family Arrangements Regulations
In Dubai, the DIFC Family Arrangements Regulations replaced the earlier single family office rules and have been in force since 31 January 2023. A Family Office is a registered person licensed as such by the DIFC Registrar of Companies. The family must meet a Minimum Net Asset Requirement, which the published text sets as an aggregate net asset value of USD 50 million, measured at fair market value where it can be ascertained and otherwise at book value.
"Family" is defined around an identified common ancestor, the ancestor's descendants and their spouses, including adopted and step-children, subject to a generational limit. The application must explain the family tree, source of wealth and funds, control and ultimate beneficial ownership, or be supported by a letter from a DIFC corporate service provider. The same Regulations create a Family Business Register and treat arbitration provisions in a family entity's governing documents as arbitration agreements, with support from the DIFC Courts.
ADGM: single family offices and Restricted Scope Companies
In Abu Dhabi, Abu Dhabi Global Market amended its single family office and Restricted Scope Company regimes with effect from 4 September 2024. A single family office must meet a minimum level of investable or liquid assets set by ADGM's rules, and can register as a private company limited by shares or as a Restricted Scope Company. An RSC keeps shareholder and director details off the public register and does not file accounts publicly, although annual returns and specified information still go to the Registrar. Confirm the current asset threshold with ADGM before applying, because it is set by rule and can change.
Federal and onshore rules
Outside the financial centres there is no dedicated family office licence. Families use holding or management licences in other free zones, or a mainland company licensed by the emirate's economic department. Federal Decree-Law No. 37 of 2022 on Family Businesses, effective from January 2023, lets onshore family companies register in a family business register kept by the Ministry of Economy and Tourism and adopt share classes and a family charter. Our article on family business law in the UAE explains those tools.
Single or multi-family office: the regulatory line
The single most important regulatory question for a family office UAE founders establish is who it serves. Managing the wealth of one defined family, through a registered family office, is generally not a regulated financial service in the DIFC or ADGM. Managing assets or giving investment advice to people outside that family is likely to be regulated activity requiring authorisation from the Dubai Financial Services Authority or ADGM's Financial Services Regulatory Authority.
The line is crossed more easily than families expect. Typical triggers include taking on a friend's or business partner's portfolio, running a co-investment club, offering the office's investment team to in-laws outside the defined family, or charging third parties fees. If a multi-family model is the plan, start with our pages on DIFC financial regulation and ADGM financial regulation, because capital, compliance and reporting obligations then apply.
| Location | Family office regime | Holding vehicles | Courts | Best suited to |
|---|---|---|---|---|
| DIFC (Dubai) | Family Office licence under the Family Arrangements Regulations; published net asset requirement of USD 50 million | Companies, DIFC foundations, DIFC trusts, prescribed companies | DIFC Courts; arbitration of family entity disputes supported | Dubai-based families wanting a full common-law toolkit and Family Business Register |
| ADGM (Abu Dhabi) | Single family office regime amended from 4 September 2024; RSC option for privacy | Companies, RSCs, ADGM foundations, trusts | ADGM Courts | Families prioritising confidentiality and Abu Dhabi ties |
| Other free zones | No dedicated regime in most zones; general holding or management licences | Free zone companies; some zones offer foundations | Usually onshore courts | Smaller offices where cost matters more than legal tools |
| Mainland | Emirate licence; federal family business registration available | Mainland companies with family charters and share classes | Federal or local onshore courts | Families whose wealth is mainly onshore operating businesses |
| Multi-family (DIFC or ADGM) | DFSA or FSRA authorisation | Regulated firm plus client structures | DIFC or ADGM Courts | Offices serving several unrelated families |
Holding vehicles beneath the family office
Most structures use three layers. At the top, a foundation or trust holds ultimate ownership and records the succession rules. In the middle, one or more holding companies own investments and operating businesses. Alongside them, the family office company provides services across the group under written agreements.
Foundations. DIFC and ADGM foundations are separate legal persons governed by a charter and by-laws, run by a council and often supervised by a guardian. Families from civil-law and Gulf backgrounds tend to find them easier than trusts, and banks are used to dealing with them as entities. See our guides to DIFC foundations and ADGM foundations.
Trusts. Both centres recognise express trusts. They suit families who already use trusts elsewhere or whose beneficiaries live in common-law countries, but some onshore registries are less familiar with trustees holding title.
Holding companies. These remain the workhorse for investments, particularly where assets need to be ring-fenced by class or jurisdiction. Where onshore real estate is involved, check early whether the relevant land registry will accept the chosen vehicle as an owner.
Tax design for a family office UAE structure
The federal Corporate Tax Law, Federal Decree-Law No. 47 of 2022, applies to companies, foundations and other juridical persons. Every entity in the chart therefore needs a tax status, and the structure should be drawn with that in mind from the outset.
Article 17 allows a foundation or similar vehicle that meets its conditions to apply to the Federal Tax Authority to be treated as a tax-transparent Family Foundation, so income is attributed to its founders or beneficiaries instead. The conditions include that it is established for identified or identifiable natural persons or public benefit entities, that it does not conduct business activities, and that its income would be personal or real estate investment income if earned by an individual. Ministerial Decision No. 261 of 2024 extended transparency to companies wholly owned and controlled by a qualifying Family Foundation, where the same conditions are met.
Two practical points follow. First, the family office company is generally taxable on its own income, including fees for managing the family's wealth; the FTA's updated guidance on family foundations, released in June 2026, confirms this, while noting that an office in a free zone carrying on DFSA- or FSRA-regulated activities may be able to access the qualifying free zone person regime if it meets the conditions. Second, a taxable company placed in the middle of the chain can break transparency for everything below it. Our corporate tax explainer covers the wider regime.
Draw the structure chart before forming any entity and mark each box as transparent, taxable or exempt, and as investing or trading. A single operating subsidiary held in the wrong place is the most common reason a family office UAE structure loses the tax treatment it was designed for. TRW & Co coordinates this review with registered tax agents; we do not act as a tax agent ourselves.
How to set up a family office: step by step
- Define the family and the objectives. Identify the common ancestor and the branches in scope, the assets to be managed, investment aims, philanthropy and who may join or leave the structure.
- Confirm single-family status. Decide whether anyone outside the defined family will ever be served. If so, plan for DFSA or FSRA authorisation instead of a family office registration.
- Choose the location and vehicles. Compare the DIFC and ADGM regimes against residence, banking, privacy and court preferences, and select the foundation, trust and company layers.
- Run the tax design. Map corporate tax status entity by entity, plan any Article 17 application, consider VAT registration for the office company and take advice in every country where family members are tax resident.
- Assemble the application pack. Prepare the family tree with civil records, source of wealth and funds evidence, net asset evidence, beneficial ownership details and draft constitutional documents.
- Register and onboard. Obtain the family office registration, incorporate the holding vehicles, and complete bank and custodian onboarding, which is often the slowest step.
- Adopt governance and personal documents. Put in place the family charter, investment policy, delegated authorities and conflicts rules, and register wills that match the structure.
- Maintain and review. File annual returns, keep beneficial ownership records current and revisit the structure when family members marry, move or inherit.
Illustrative scenario: a founder consolidating three generations
The following scenario is illustrative only and does not describe any client.
A founder resident in Dubai owns an onshore trading group, a portfolio of listed securities held through a European bank, and several Dubai apartments in his own name. His two adult children live in Dubai and London; a third is still at university. He wants a professional office to manage investments, a clear route for control to pass to the next generation, and no probate delays.
A typical design would be a DIFC foundation holding a DIFC holding company, which owns the investment portfolio and, after a restructuring, the shares in the trading group's holding entity. A separate DIFC Family Office company employs the investment staff and charges the group under a service agreement. The apartments are reviewed asset by asset against land registry rules before any transfer. The trading group, as an operating business, sits in a separate taxable branch of the chart so that the investment branch can be assessed for transparency.
The London-resident child obtains UK advice on how the foundation will be classified there, and the founder registers a will covering anything left in his own name.
Risks and common mistakes
Drifting into regulated activity
A single family office that starts managing money for a business partner, a friend or a wider circle of relatives outside the defined family risks carrying on regulated financial services without authorisation. The DIFC and ADGM regimes are generous to genuine single family offices precisely because they do not serve outsiders. Before accepting any third-party money, co-investment or fee, check the family definition in the relevant regulations and whether DFSA or FSRA authorisation is needed. Unwinding an unauthorised arrangement later is expensive and can damage banking relationships.
Assets never transferred into the structure
Families often register a foundation and a family office, then leave the property, shares and bank accounts where they were. On death, those assets pass through ordinary succession, are frozen in the meantime and may be distributed under default rules. Build the asset transfers into the project plan with owners and deadlines. Where an asset cannot be moved quickly, such as mortgaged property or shares subject to pre-emption rights, deal with it expressly in a registered will until it can be transferred.
Treating the office as tax neutral
Many families assume a free zone family office pays no corporate tax. In fact the office company is generally taxable on its fees, and free zone relief depends on meeting strict conditions. Transparency for a family foundation also depends on conditions that must remain true every year: a trading subsidiary or a taxable company in the chain can undermine it. Review the chart annually with a registered tax agent, especially after acquisitions, new investments or changes in family residence.
Governance that exists only on paper
A council that never meets, a charter no one has read and investment decisions taken informally by the founder all weaken the structure. They make it harder to show that the foundation, not the founder, controls the assets, which matters for asset protection and for tax in other countries. Hold scheduled meetings, minute decisions, follow the delegated authority matrix and plan how the next generation is trained to take over seats on the council or board.
Ignoring beneficiaries' home-country tax
A UAE structure that works perfectly locally can create unexpected tax for a child living in the UK, India or elsewhere. Foreign tax authorities may classify a foundation as a company, a trust or something else, with very different results for distributions and reporting. Obtain advice in each relevant country before choosing between a foundation and a trust, and review it whenever a family member changes residence.
Cross-border points for families relocating to the UAE
Many families establish a family office UAE base when they relocate from the UK, India, South Asia, Europe or elsewhere in the Gulf. The move usually works best when residence, tax and structure are sequenced together. Long-term residence for family principals and key staff should be planned alongside the structure; our guide to the UAE Golden Visa explains the investor categories, including the property route with a minimum of AED 2 million.
Exit rules in the departure country matter as much as UAE rules. Some countries tax unrealised gains on departure, look through foreign structures, or keep individuals within their inheritance tax net for years after leaving. Assets held abroad remain subject to local succession and property law, so a UAE foundation may need to sit alongside local holding vehicles or wills. For Bangladesh-, Singapore- and UK-connected families, TRW & Co's offices can coordinate the home-country side with the UAE design.
Checklist: what to do next
- Write down the family definition, the assets in scope and whether anyone outside the family will ever be served.
- Compare DIFC and ADGM on asset thresholds, privacy, courts and where the family lives and banks.
- Prepare a structure chart showing ownership, management and tax status for every entity.
- Start the source-of-wealth file early; it drives both registration and bank onboarding timelines.
- Align wills, the foundation charter and the family charter so they do not contradict one another.
- Diarise annual reviews of governance, tax status and family residence.
To discuss a family office UAE structure for your family, contact TRW & Co at info@trw.co or +971 58 942 1012. We advise from Dubai and coordinate with registered tax agents, corporate service providers and, where court work is needed, locally licensed advocates and registered DIFC and ADGM practitioners.
Frequently asked questions
01How much wealth is needed to set up a family office in the DIFC?
The published DIFC Family Arrangements Regulations define a Minimum Net Asset Requirement of USD 50 million in aggregate net asset value, measured at fair market value where possible and otherwise at book value. It is assessed across the family rather than per person. ADGM applies its own threshold for single family offices, based on investable or liquid assets. Because thresholds are set by rule and can change, confirm the current figure with the relevant registrar before preparing an application.
02Does a single family office in the UAE need a financial services licence?
Generally not, if it serves only the family defined in the DIFC or ADGM rules and registers under the relevant family office regime. Once it manages assets or gives investment advice to people outside that family, it is likely to be carrying on regulated activity requiring DFSA or FSRA authorisation. Co-investment arrangements, fee-charging and taking on friends' portfolios are the usual ways families cross the line without realising it.
03Should our family office be in the DIFC or ADGM?
Both offer common-law courts, foundations, trusts and a family office regime. The DIFC has a published USD 50 million net asset requirement, a Family Business Register and support for arbitrating family disputes. ADGM lets single family offices use a Restricted Scope Company, which keeps owners and directors off the public register. Practical factors often decide it: where the family lives, its banking relationships, which emirate its businesses are in, and preferred service providers.
04Is a UAE family office subject to corporate tax?
The family office company is generally taxable on its income, including fees for managing the family's wealth, under Federal Decree-Law No. 47 of 2022. A family foundation that meets the Article 17 conditions can apply to be treated as transparent, and Ministerial Decision No. 261 of 2024 extends that to qualifying wholly owned companies. A free zone office doing DFSA- or FSRA-regulated activities may be able to access qualifying free zone treatment if it meets the conditions.
05Do we still need wills if the family office and foundation hold our assets?
Yes. A foundation controls only assets actually transferred into it. Bank accounts, vehicles, property and shares left in an individual's name still pass under the succession rules that apply to that person, and are typically frozen on death until a court order or grant is obtained. Non-Muslim residents can register wills with the DIFC Courts or the Abu Dhabi Judicial Department. Wills elsewhere should be coordinated so they do not contradict the UAE structure.
06How long does it take to set up a family office in the UAE?
The registrar process is usually the shorter part. Timing depends mostly on how quickly the family can produce family tree documents, source-of-wealth evidence and net asset proof, on drafting the foundation and governance documents, and on bank and custodian onboarding, which commonly takes longest. Families with assets in several countries should also allow time for foreign tax advice before assets are transferred.
Sources and official materials
- DIFC Family Arrangements Regulations — Family Office licence, net asset requirement and Family Business Register
- Abu Dhabi Global Market — ADGM registration authority, single family offices and foundations
- Federal Decree-Law No. 47 of 2022 on Corporate Tax — Article 17 family foundation treatment
- Federal Tax Authority — Corporate tax guides, including family foundations
- Federal Decree-Law No. 37 of 2022 Concerning Family Businesses — Onshore family business registration and charters
- DIFC Courts — Courts supporting DIFC family entities and arbitration
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
