The Federal Tax Authority has recently issued an updated version of the Corporate Tax Guide on the Taxation of Family Foundations (2026), replacing the prior edition released in May 2025.
Whilst the overarching legislative framework remains unchanged, the updated guidance introduces clarifications and refinements regarding the application of the UAE Corporate Tax regime to Family Foundations and related structures. In particular, the new guidance addresses several areas that were not expressly covered in the previous edition, thereby reducing interpretative uncertainty and delineating the intended scope of the regime more clearly.
In particular, the updated guidance:
- enhances certainty regarding asset transfers into Family Foundations;
- confirms limitations on tax basis adjustments;
- restricts access to fiscal transparency for operational entities (e.g. family offices); and
- expands structuring flexibility through the recognition of multi-family ownership arrangements.
In this Alert, our Middle East Managing Partner, Olivier Remacle, and our Tax Principal, Barbara Schwartz, summarise the key developments arising from the new guidance and their practical implications.