UAE Law and Practice Contributed by: Ildar Yuvakaev, Ruslan Akhmetov, Olga Serova and Daiana Ubushaeva, Consigliere Group
Moreover, the existing tax regime remains in a phase of practical implementation. In particular, the tax regime continues to develop through administrative guidance issued by the Federal Tax Authority. However, at present, no material changes to taxes have been announced. 1.7 Transparency and Increased Global Reporting The UAE participates in the OECD Common Reporting Standard (CRS) automatic exchange of information, has implemented the US Foreign Account Tax Com - pliance Act (FATCA) through an intergovernmental agreement with the United States, and has adopted various OECD Base Erosion and Profit Shifting (BEPS) measures. The UAE will implement the OECD’s updated Com - mon Reporting Standard (CRS 2.0) from 1 January 2027, with first information exchanges scheduled for 2028. The revised framework expands reporting obli - gations to cover additional financial products, includ - ing certain electronic money products and central bank digital currencies, and aligns its implementation with the OECD’s Crypto-Asset Reporting Framework (CARF), extending international tax transparency to crypto-assets and other digital financial assets. While CRS 2.0 expands the automatic exchange of information, CARF establishes a separate reporting framework requiring crypto-asset service providers to collect and report information on customers’ crypto- asset transactions to the relevant tax authorities for subsequent automatic exchange between participat - ing jurisdictions. Beneficial ownership transparency is reinforced through requirements for companies to identify, main - tain and, where required, submit information on their ultimate beneficial owners (UBOs). However, the UAE does not currently maintain a fully public beneficial ownership register. The UAE has not implemented the EU DAC6 reporting regime, as it is not a member of the European Union. However, transactions involving EU intermediaries or
taxpayers may still give rise to DAC6 reporting obliga - tions outside the UAE.
2. Succession 2.1 Cultural Considerations in Succession Planning UAE private wealth is often connected to founder-led family businesses, large family groups and assets held across several jurisdictions. Founders may be willing to transfer economic value but reluctant to surren - der voting control, particularly where only some fam - ily members participate in the business. This makes staged succession, separate voting and economic rights, and clear entry, employment and dividend poli - cies especially useful. The Federal Family Business Law gives statutory rec - ognition to family charters, family councils and fam - ily offices, and permits differentiated share rights. A charter can record the family’s values and governance principles, but the articles of association prevail if the two conflict. Terms intended to be enforceable – such as transfer restrictions, voting arrangements and valu - ation mechanisms – should therefore also appear in the constitutional or ownership documents. 2.2 International Planning Succession planning in the UAE must be asset-spe - cific rather than based on a single assumption about residence. Under the Civil Transactions Law effective from 1 June 2026, succession is generally governed by the law of the deceased’s nationality at death. A will may designate the law governing its substantive and formal validity, but UAE law applies to a foreigner’s will concerning UAE immovable property, and special personal-status legislation may also apply. A practical plan should map each asset, its situs, the competent court, the applicable marital-property and forced-heirship rules, and any foreign estate or inheritance tax. UAE and foreign wills should be co- ordinated so that one does not revoke the other. For non-Muslims, a registered UAE will can materially reduce uncertainty. Foundations, trusts and holding companies may assist with continuity, but only after
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