FTA Issues Guidance on Corporate Tax for Family Wealth Management Structures

The Federal Tax Authority (FTA) has released new Corporate Tax Public Clarification (CTP008) clarifying the corporate tax treatment of family wealth management structures under the UAE Corporate Tax Law. This guidance provides essential clarification for families, advisors, and corporate service providers managing complex ownership and investment arrangements. 

Key Highlights 

1. Typical Structure Components - A family wealth management structure commonly includes: 

• Family foundation 

• Holding company 

• Special-purpose vehicle (SPV) 

• Single-family office (SFO) or multi-family office (MFO) 

• Family members 

2. Tax Transparency 

• Family foundations or other vehicles without separate legal personality are automatically treated as tax transparent. 

• Foundations with separate legal personality may apply to the FTA for tax transparent status if they meet the conditions under Article 17(1) of the Corporate Tax Law. 

• This treatment also extends to holding companies or SPVs wholly owned and controlled by a tax transparent foundation. 

3. Taxable Entities 

• Any family wealth management vehicle with separate legal personality that does not meet Article 17(1) conditions is regarded as a taxable person in its own right. 

4. Family Offices 

• Both SFOs and MFOs are considered juridical persons and taxable on all income, including management fees and other revenues. 

5. Treatment of Family Members 

• Family members are not subject to corporate tax on income derived from: 

• A taxable family wealth management vehicle; or 

• A tax transparent trust, foundation, or similar entity qualifying under Article 17(1). 
  Such income is classified as personal investment or real estate investment income. 

Publication Details 

FTA Corporate Tax Public Clarification (CTP008)  on the corporate tax treatment of family wealth management structures was officially published on 19 September 2025.