Structuring Wealth in the Middle East: Private Client Horizons

Authored by Debora Krasniqi, Associate | January 28, 2026

The private-client landscape in the Middle East has matured at remarkable speed. What was once a patchwork of offshore holding companies in different free zones has evolved into sophisticated regimes – both in free zones and onshore – designed for dynastic planning, governance, and tax efficiency.

For families with operating businesses and cross-border lives, the region now offers credible “home-base” solutions built around foundations, trusts, councils, and family-business frameworks that reflect common-law standards while remaining culturally attuned.

Why the Middle East, and Why Now?

Three structural shifts underpin the momentum currently transforming the regional private-wealth market.

The first is institutional scale. The Abu Dhabi Global Market (ADGM) and the Dubai International Financial Centre (DIFC) have grown rapidly, attracting global managers, family offices, and professional infrastructure that creates a more coherent local capital-markets ecosystem. ADGM alone issued 1,271 new licences in the first half of this year, now hosting 112 fund managers overseeing 141 funds, and adding more than 2,500 employees to its workforce.¹ This pace of development, reinforced by major entrants such as the $1.33 trillion asset manager PGIM opening an Abu Dhabi office has cemented ADGM’s position as the region’s fastest-growing financial centre.²

The second shift is the modernisation of “family infrastructure.” DIFC’s 2023 Family Arrangements Regulations introduced a cohesive governance framework that works alongside its existing trusts and foundations regime. The DIFC defines a family entity as any entity which has a legal existence separate and distinct from a person and that is established for the sole purpose of holding, investing, operating or utilising assets of a Family, or a Family Structure or the proceeds thereof or the succession or legacy planning of Family assets, or the benefits or proceeds derived therefrom and is controlled by a Family.³

This framework supports family charters, councils, voting protocols, and formal governance architecture, giving families a regulatory backbone for decision-making and long-term continuity.

The third shift is regulatory certainty. The UAE’s corporate tax regime, introduced at a globally competitive 9% rate,⁴ is now bedding in with clarifications that are increasingly tailored to private-client structures, including the treatment of family foundations.

The main purpose of a family foundation cannot be for the avoidance of corporate tax.

Article 17(1)(a)-(e) of Federal Decree-Law No. 47 of 2022, as amended by Ministerial Decision No. 261 of 2024, permits a family foundation, trust, or other entity to elect Unincorporated Partnership status.⁵ This election renders the Family Foundation fiscally transparent, as per Article 16 of the same act, therefore, taxing income, assets, and liabilities to beneficiaries rather than taxing the entity. Article 11(6) and Cabinet Decision No. 49 of 2023 then exclude natural persons’ “Personal Investment” and “Real Estate Investment” income from Corporate Tax, so individual beneficiaries can achieve a 0% corporate tax outcome on passive portfolios and UAE real estate held through a transparent Family Foundation.⁶ Article 4, 9, 22 and 23, exempt Qualifying Public Benefit Entities and certain dividends and gains on qualifying participations, that include institutional and charitable beneficiaries from Corporate Tax where such criteria are satisfied and all residual non-exempt income is subject to the standard rate of tax.⁷

Parallel reforms in personal-status law (particularly the 2022 Civil Personal Status regime applicable to non-Muslims have reduced uncertainty around marriage, divorce, inheritance, wills, and parentage, significantly lowering cross-border conflict-of-laws risk. Article 1, expressly allows for non-Muslim foreigners to opt for their home country’s law for marriage, divorce, inheritance and parentage.⁸

Together, these developments have created a landscape that supports regulated, onshore, governance-driven wealth planning, an environment previously lacking in the region.

Foundations: The New Centre of Gravity

Foundations have become the preferred structural anchor for many regional families, especially within ADGM, DIFC, and RAK ICC. As purpose-driven vehicles, they separate economic benefit from control, avoid share-transfer formalities, and allow governance principles to be embedded directly into charters, by-laws, and confidential letters of wishes. This makes them ideal for holding operating businesses, real estate portfolios, investment companies, and investment or cash accounts under a single, durable structure.

RAK ICC: Refreshed and Flexible

The RAK ICC Foundations Regulations 2019 were significantly updated in 2025 to strengthen succession-planning and asset-protection capabilities.⁹ The enhancements refine definitions, clarify application scope, and reinforce governance safeguards, part of a broader policy objective to create a robust, internationally credible regime. Complementary updates in economic-substance guidance and compliance expectations ensure that holding vehicles remain aligned with operational realities, especially when owning active subsidiaries.

DIFC and ADGM: Common-Law Comfort

In the DIFC, the Family Arrangements framework works together with existing trusts and foundations rules, enabling cohesive governance.¹⁰

Another popular vehicle, a DIFC foundation, may hold operating shares, while the council determines distribution policy, board-appointment rights, and internal dispute-resolution pathways. This creates a strong alignment between ownership and family governance.

ADGM: Governance Architecture, Control Rights, and Dispute Resolution Alignment

ADGM, meanwhile, remains the jurisdiction of choice for families that value the direct application of English common law and a rapidly expanding professional services market. Its courts, regulatory clarity, and depth of advisers have made it a preferred platform for complex, multi-jurisdictional structures.¹¹

Succession and Personal-Status Reforms: Fewer Grey Areas

Historically, succession has been one of the most challenging issues for expatriates and mixed-nationality families in the UAE. The Civil Personal Status regime (Federal Decree-Law No. 41 of 2022), effective from 2023 for non-Muslims, has materially improved predictability by clarifying rules on inheritance, wills, marriage, divorce, and parentage. Crucially, it allows the application of an individual’s home-country law in defined circumstances.¹²

For private-client practitioners, this reduces conflict-of-laws risk and increases the reliability of local wills, foundation by-laws, and succession protocols transforming UAE-based planning from a fragmented process into a stable, internationally aligned one.

A Future-Proofed Blueprint for Families

Sophisticated regional families are increasingly embracing integrated, ecosystem-based planning that blends governance, ownership, tax administration, and succession into a single coherent structure.

At the centre is a UAE foundation, acting as the dynastic anchor and holding core family assets. Charters and by-laws articulate purpose, beneficiaries, and control arrangements while embedding conflict-management rules and predetermined dispute-resolution mechanisms. Beneath the foundation, UAE free-zone SPVs house operating companies, investment vehicles, and financing platforms. This architecture supports compliance with Economic Substance Regulations and transfer-pricing expectations, ensuring operational and regulatory coherence across borders.

With corporate tax now entrenched, families are increasingly examining whether their foundations qualify for the Federal Tax Authority’s Unincorporated Partnership treatment via EmaraTax; an option that may streamline or reduce filing obligations.¹³

Succession instruments, including UAE-recognised wills, are drafted often in parallel with the foundation’s governing documents. This alignment ensures that testamentary intent and structural mechanics work in concert, reducing forum shopping and preventing inconsistent outcomes. Together, these components create durable, future-proofed ecosystems capable of protecting assets, preserving family unity, and enabling smooth generational transitions.

Outlook: A Region Converging Toward Global Best Practice

Across the Gulf, competition among leading financial centres is intensifying, but so is convergence. RAK ICC’s enhancements to its foundations regime, the DIFC’s increasingly comprehensive family-wealth framework, and ADGM’s rapid expansion collectively demonstrate a shared policy direction making it seamless for families to be onshore, compliant, and well-governed.

The Federal Tax Authority continues to refine corporate-tax guidance applicable to family foundations, giving private-wealth structures a level of predictability previously unavailable in the region.

Taken together, these developments offer globally mobile families a credible, sophisticated alternative to traditional offshore jurisdictions. The Gulf today is not just an operational base but an increasingly compelling jurisdictional home, one that blends stability, legal clarity, and long-term strategic advantage.

It is a horizon well worth seizing.

For more information, consult the key sources listed below.

1. FinTech News Middle East, ‘Global Companies Expand to ADGM: A Look at the Latest Fintech Players Establishing Presence in Abu Dhabi’ (2 September 2024). Available at: fintechnews.ae (Accessed: 24 November 2025).

2. Maccioni, F., ‘PGIM opens Abu Dhabi office, joining money managers’ rush to UAE capital’ (Reuters, 12 September 2024). Available at: reuters.com (Accessed: 24 November 2025).

3. DIFC Family Arrangements Regulations, Rule 2.3.1 (January 2023). Available at: difc.com (Accessed: 24 November 2025).

4. Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, Article 3. Available at: tax.gov.ae.

5. Ibid, Article 17.

6. Cabinet Decision No. (49) of 2023 on Specifying the Categories of Businesses Subject to Corporate Tax. Available at: mof.gov.ae.

7. Federal Decree-Law No. 47 of 2022, Articles 4, 9, 22, 23. Available at: tax.gov.ae.

8. Federal Decree-Law No. (41) of 2022 on Civil Personal Status, Article 1. Available at: uaelegislation.gov.ae.

9. Ras Al Khaimah International Corporate Centre (RAK ICC), ‘RAK ICC Strengthens Foundations Regime with 2025 Legislative Enhancements’ (Press Release, 14 August 2025). Available at: rakicc.com (Accessed: 24 November 2025).

10. DIFC, ‘Enactment of New DIFC Family Arrangements Regulations’ (Announcement, 2023). Available at: difc.com.

11. ADGM Courts, Guidance on English Common Law. Available at: adgm.com.

12. Federal Decree-Law No. (41) of 2022 on Civil Personal Status, Article 1. Available at: uaelegislation.gov.ae.

13. Federal Tax Authority (FTA), ‘Launch of Family Foundations as an Unincorporated Partnership application via EmaraTax Digital Platform’ (March 2025). Available at: tax.gov.ae.

This article is originally published in ThoughtLeaders4 Middle East Magazine, “MAPPING THE LANDSCAPE” — Inaugural Issue: Private Wealth, Complex Assets & Cross-Border Matters, Issue 1, January 2026.