UAE Trends and Developments Contributed by: Ildar Yuvakaev, Ruslan Akhmetov, Svetlana Koronova and Sofia Simonova, Consigliere Group
Crypto-Asset Reporting Framework (CARF) and rein - forcing international tax transparency for both tradi - tional financial assets and crypto-assets. Taxation The UAE’s private wealth tax framework continued to evolve during 2026. Taxation on Family Foundations (CTGFF1) The updated Corporate Tax Guide on Family Founda - tions issued by the UAE Federal Tax Authority (FTA) in June 2026 does not alter the fundamental principles of the regime. However, it clearly reflects a broader evo - lution in the taxation of private wealth structures in the UAE. Where the original objective of the regime was to ensure tax neutrality for succession planning and the preservation of family wealth, the latest clarifications indicate a shift towards a more structured and granu - lar framework for supervising complex multi-layered ownership arrangements. One of the most significant developments is the con - firmation that a single juridical person may be jointly owned by more than one Family Foundation. At the same time, the FTA indicates that transparency is pre - served only where there is an uninterrupted chain of fiscally transparent ownership. The presence of any entity that does not meet the requirements of Article 17 of the Corporate Tax Law may break this chain, resulting in the relevant company becoming a sepa - rate taxable person. Equally important is the clarification that the benefi - ciary condition is automatically extended to juridical persons that are wholly owned and controlled by a Family Foundation that meets the beneficiary condi - tion. Family offices At the same time, the FTA draws a clearer distinction between passive asset holding and active business operations. The new section on single family offices (SFOs) and multi-family offices (MFOs) confirms that family offices carrying out management and advisory functions will generally not qualify for tax-transparent treatment and will remain taxable persons. This effec - tively reinforces the principle that tax transparency is
intended for capital ownership and preservation, rath - er than for service provision or commercial activity. Transfer pricing A particularly notable development is the increasing role of transfer pricing within the private wealth space. The updated guidance explicitly requires compliance with the arm’s length principle in relation to asset transfers and funding arrangements involving Family Foundations and related parties. This reflects a broad - er trend in the UAE tax system, where transfer pric - ing rules are gradually extending beyond traditional corporate groups to encompass family structures and family office arrangements. In this context, the recent FTA Public Clarification CTP010 regarding directors and officers is also sig - nificant. The tax authority confirmed that where an individual qualifies as both a related party and a con - nected person, the individual will be treated solely as a related party for the purposes of the Corporate Tax Law. This is relevant from a disclosure perspective, as the two classifications (related party and connected person) are subject to different reporting thresholds. Corporate Governance and Mainland Company Reform Amendments to the UAE Commercial Companies Law The 2025 amendments to the UAE Commercial Com - panies Law have given mainland companies a wider set of tools for structuring control and protecting shareholders. For private clients and family business - es, this matters because the company documents can now deal more precisely with ownership, voting rights, exits and succession. Use of different classes of shares One important change is the ability to use different classes of shares or quotas. These instruments may carry different voting rights, dividend rights, liquida - tion priority or redemption rights. In a family business, this allows the founder to separate economic benefit from control. For example, passive heirs may receive financial rights, while voting powers remain with the founder, active family members or a holding vehicle. The relevant rights should be reflected in the consti -
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