UAE Wealth Structuring 2025: New Laws, Foundations, Wills and Global Family Office Trends
The UAE has entered a decisive new phase in private-wealth planning. A wave of new federal laws, strengthened DIFC and ADGM courts, and a sharper focus on cross-border succession are transforming how ultra-high-net-worth families protect assets, register wills and structure their global estates.
On the 12th May 2026, Citywealth will discuss conflicts in different laws at our Citywealth annual Forum, the day before the Citywealth Magic Circle Awards. Agenda here. The segment is called Crossroads of Sharia and Common Law, Jewish law and other religious legal conflicts. Unexpected pitfalls, from forced heirship conflicts to cross-border enforceability issues. We will also include halachic (Jewish law) and other religious laws.
Dubai update 2025
With Dubai Law No. 2 of 2025 reshaping the rules on non-Muslim inheritance and foundations becoming central to governance, the UAE is rapidly positioning itself as one of the most sophisticated and internationally relevant wealth hubs in the world.
The UAE’s private-wealth landscape is undergoing one of its most significant periods of reform and consolidation in decades. A series of new federal laws, expanding free-zone frameworks and upgraded courts are transforming how families, both local and expatriate, plan succession, manage global assets and structure family governance. With rising migration from the UK, Europe, Asia and Latin America, the DIFC and ADGM have reached a point of critical mass, emerging as trusted centres for estate planning, corporate structuring and next generation wealth management. Against a backdrop of demographic change and a sharp increase in non-Muslim residents, the UAE is redefining itself as a long-term base for internationally mobile families seeking certainty, flexibility and institutional-grade solutions. Increasingly, this is playing out through the way wills are drafted, succession is organised and family businesses are structured. Non-Muslim expatriates, Muslim families with international assets and global family offices are having to decide which laws and which courts will govern the transfer of their wealth.
However, Joshua S. Rubenstein, Partner, National Chair, Katten, New York says, “There is no question that Dubai has become a top contender for wealth management and structuring from a trust and family office perspective. It is of particular interest to wealth creators from India and Russia, particularly because of its geographic and time zone proximity.”
“I am not seeing its popularity among American clients, however. On the one hand, Dubai’s trust code is borrowed from the U.S. Uniform Trust Code, so it is familiar. On the other hand, American families tend to be litigious, and Dubai’s laws are so new that they have not yet been tested in the courts. The Channel Islands, Cayman and Bermuda have hundreds of years of case law precedent, making it easier to predict case outcome, and they are closer.”
A New Legal Framework for Succession Planning in the UAE
Of the local laws, David Russell KC, Barrister, Outer Temple Chambers, says: “Both UAE Federal and Dubai Laws make express provision that non-Muslims can make wills in accordance with their own national laws. In the case of Dubai that can be done through the DIFC Courts Wills and Probate Registry, supervised by the DIFC’s (common law) Courts. Assets outside the UAE can be disposed of in the same way, although enforcement in the jurisdictions concerned will depend in their own laws on the topic.”
“In general, Muslims are free to dispose of their assets during their lifetimes by unconditional gifts called ‘heba’ subject to them having the necessary capacity (a concept not unlike the common law test of testamentary capacity). Structures such as Foundations or Trusts are also available and UAE Federal Law recognises the validity of dispositions of property to these in the context of family businesses. In short, the reported problems are most likely to arise through lack of well thought out succession planning.”
He adds,as Rubenstein did, that, “Most of the laws which clarify matters are quite recent, for instance. Federal Family Business Law (2022), Federal Trust Law (2023) and Federal Personal Status Law (2024). The DIFC Trust and Foundations Laws date from 2018.”
What it suggests. The UAE has only relatively recently put in place a modern, codified framework for family businesses, trusts and foundations, and personal status and succession. There may still be gaps, test cases and evolving practice, simply because this is not a one hundred year old regime like English trust law. With the legal landscape now clearer, attention is turning to how these reforms are reshaping the tax position and operational structure of UAE foundations.
How Foundations and Tax Transparency Are Changing Wealth Structures
Jonathan Burt, Partner, Charles Russell Speechlys, brings over 30 years of experience to his perspective.
“There has been the introduction of corporation tax in the UAE which subjects business profits to tax at 9%. The UAE government also recently introduced the possibility for a foundation to apply to be treated as fiscally transparent. This works well if the principal activity is related to investments and has helped to clarify the tax treatment of Foundations. If the foundation’s activities are passive in terms of receiving investment income and real estate income, the beneficiaries are exempt from tax if the structure is transparent.”
“It has also been important that the option for tax transparency was extended to wholly owned subsidiaries. This has helped to provide an option for individuals who manage and control an overseas company from the UAE. If the company is transferred to a Foundation, then it is possible for that entity to be treated as fiscally transparent too.”
“Generally, we are seeing DIFC Foundations being used to plan the succession of significant UAE trading businesses. This means that the Foundations are becoming more sophisticated in their application, and there is more focus on corporate governance and succession planning.”
“The government introduced DIFC Foundations in 2018, so they are quite recent. I am continuing to see interest in setting up structures in jurisdictions which have a track record and a history of reliability. Of course there may be issues, eg: Emirates NBD Bank won a judgment in Jersey, Channel Islands, to recognise and enforce a Dubai Court order against a UAE national in the Almakhawi trust matter. That was a case about putting assets beyond the reach of a creditor where the settlor of a trust had guaranteed bank lending which got called in.”
“I am certainly aware of wealthy owners and business owners leaving the UK for the UAE. This is obvious from my own practice. I understand that many new arrivals are from Asia. Generally I think that the DIFC and ADGM have really started to gain critical mass and that is seen by its positioning as, for instance, a gateway into and out of Africa.”
The Almakhawi matter clarified an important point for enforcement. It was an unusual case involving a bank, where Emirates NBD sought recovery of lending that had been guaranteed by the borrower. The assets in question had been moved into a Jersey, Channel Islands, trust after the lending was called in, but the Royal Court of Jersey recognised and enforced the Dubai court judgment. The trust could not be used to keep those assets out of the bank’s reach. It demonstrated that attempts to use offshore structures to sidestep UAE bank enforcement are unlikely to succeed where there is a clear judgment in Dubai.
As these structural tools mature, the market itself is evolving.
Rising Demand for UAE-Based Governance and Family-Office Platforms
Dipali Maldonado, Partner and Head of Private Client at Al Tamimi and Company, says: “What we are seeing today is that the UAE’s private-wealth market has entered a clear maturity phase. High-net-worth individuals and families, whether local, long-term expatriates, or newly arrived from the UK, Europe, India, Latin America or China, are no longer asking whether to structure in the UAE, but how. Increasingly, they are seeking to establish UAE-based structures such as trusts, foundations, family offices and corporate entities to run their businesses, alongside securing golden visas and registering wills, prenuptial or postnuptial agreements. These asset-protection measures are becoming standard for individuals relocating to a jurisdiction with a different legal framework. We are also seeing a notable rise in the use of Abu Dhabi Civil Family Court wills, particularly among Muslims from non-Muslim countries and the DIFC also remains very popular for non-Muslims seeking to register wills.”
“Although many families still maintain parallel offshore structures, keeping offshore assets abroad while placing UAE or regional assets under local entities, there is growing demand for UAE vehicles to serve as central holding and governance hubs. Families increasingly want a UAE-based, locally managed, yet internationally compatible framework. As a result, we collaborate closely with international counsel across multiple jurisdictions to diligence assets and advise on optimal cross-border structures.”
“The most prominent trends are: 1. Consolidation, simplifying legacy offshore platforms under a UAE governance layer. 2. Professionalization, upgrading family-office capabilities within DIFC and ADGM and relocating CIOs and professional staff to the UAE. 3. Mobility, a continued influx from Europe, the US, India, Asia and Latin America drawn by the UAE’s lifestyle, safety, tax stability and geopolitical neutrality.”
“Challenges can arise when individuals or families don’t seek or get tailored advice, the trap of ‘one size fits all’, or assets are not properly diligence at the outset. We sometimes see clients establish a DIFC or ADGM foundation only to learn later that certain assets cannot be contributed due to regulatory restrictions, or that the structure creates funding or financing obstacles, issues that should have been identified from the outset. Additional risks emerge when structures do not keep pace with an individual’s asset growth, which can result in bank accounts or companies being frozen upon the individual’s death, fragmented ownership, governance complications and enforceability gaps between foreign and UAE courts.”
“Overall, the UAE has evolved from a destination for the globally mobile elite into a pivotal hub for structuring international wealth, family offices and global capital with the profile of newcomers being increasingly sophisticated and institutional.”
“Abu Dhabi, setting up an efficient family court in the Abu Dhabi Civil Family Court that implements a law for non-Muslims and Muslim foreigners, a law that is based on secular principles is another step in positioning itself as an international centre for the wealthy. Whilst we do not have the high stakes in terms of values of court judgments or ability to claim 50 per cent of net worth built up during marriage like London for example, the court does give the ability to file divorces quickly and remotely which has proven to be a benefit to the mobile wealthy.”
“To give you some stats, the Abu Dhabi judiciary has registered 15,000 civil marriages and 7,600 wills in 9 months (Jan to Sept 2025) so it is indeed a very popular court. No divorce stats have been published by the courts as yet.”
For UHNW families, Abu Dhabi’s Civil Family Court is becoming an important onshore alternative to the free zones. It lets people register civil marriages and wills under clear rules set by the court, rather than through religious processes. This is proving attractive to Muslims from non-Muslim countries and to internationally mobile couples who want a quick, straightforward procedure that is recognised in the UAE.
This shift is increasingly international, as cross-border families integrate UAE entities into wider global platforms.
Multi-Jurisdictional Structures and the Challenge of Enforcement
Alessandro Umberto Belluzzo TEP, Barrister, Founding Partner, Belluzzo International Partners, says: “The UAE, Dubai and Abu Dhabi are our main focus, continues to cement its position as one of the world’s most attractive hubs for UHNW individuals, drawing record inflows of global wealth and consolidating its reputation as a jurisdiction that combines lifestyle appeal with increasingly sophisticated legal and financial infrastructure. What makes today’s market particularly interesting is the demographic reality, around a quarter of the UAE’s population is now non-Muslim, a multinational community that brings with it diverse succession expectations, governance styles and asset-protection needs. As a result, estate-planning behaviour is evolving rapidly.”
“One visible trend is the sharp increase in non-Muslim expatriates registering wills in the DIFC ADGM courts. The local authorities have made significant progress in offering predictable, common-law-style inheritance frameworks for foreign nationals who wish to avoid the default Sharia-based intestacy rules that would otherwise apply to assets situated in the UAE.”
“The process has been simplified, and for many UHNW families it is now a mandatory part of establishing a presence in UAE. Where this step is skipped, problems tend to arise, particularly around real estate and bank accounts, which can be frozen until the courts determine succession outcomes.”
“Another defining theme is the expansion of multi-jurisdictional structuring, especially among families with business interests or real estate spanning the UAE, Europe and the Crown Dependencies. Wealthy families increasingly deploy a combination of Jersey or other trusts, UAE holding companies, DIFC wills and European investment structures. This layering can be effective, but it also requires careful governance to avoid fragmentation or conflict. A number of recent disputes illustrate the challenge, offshore trusts owning UAE assets have become embroiled in litigation when a locally based family member, often a son or key operator, informally assumes practical control of the assets, sometimes contrary to the parents’ stated wishes. These conflicts can escalate into major arbitration or court proceedings in Jersey or other trust jurisdictions. Therefore, I think the best option is the use of UAE Foundations to hold assets and manage the family governance.”
“Enforcement remains another area of sensitivity. Judgments and orders issued in one jurisdiction, such as Jersey, are not automatically enforceable across all others, including the UAE. UHNW families therefore need dispute-resolution clauses, enforcement strategies and occasionally local security arrangements in place at the structuring phase, not once a conflict arises. As family configurations become more international, preventing deadlock becomes just as important as asset protection.”
“On the opportunity side, UAE’s real estate market remains exceptionally strong, supported by sustained UHNW migration, attractive residency rules and a good regulatory environment. This has drawn not only British, Russian, Indian and Middle Eastern families, but an increasing number of Europeans, including British and Italians. Italian clients are looking at UAE as part of a multi-centre lifestyle, combining personal mobility, lower tax and real-estate investment with business platforms in Europe.”
“Overall, the UHNW landscape in UAE remains positive, but more complex than headlines suggest. The jurisdiction’s openness is matched by a need for clear governance, coordinated estate planning and multi-jurisdictional awareness. For globally mobile families, UAE offers opportunity, provided their structures can keep pace with their ambitions.” Belluzzo clarifies on his UAE reference. “I refer to Abu Dhabi and Dubai as the main hubs for UAE.” Continuine he finishes saying. “These structural changes coincide with a major demographic transition, led by younger wealth creators and new investment behaviours.”
Next-Generation Wealth and the Shift in Family Governance
Ali Janoudi, Region Head New Markets, Partner of Lombard Odier Group, says: “Dubai is amid one of the most significant wealth transitions globally, with an estimated multi-billion-dollar transfer to the next generation already underway. We’re seeing far younger wealth creators, many under 40, driving investment decisions and demanding greater transparency, digital access and portfolios that reflect their values. Families are also professionalising their governance frameworks at a pace we haven’t seen before, with succession, cross-border structuring and long-term legacy planning now top of the agenda. At the same time, Shariah-compliant and sustainable strategies continue to gain momentum as investors seek more purposeful deployment of capital. These shifts are transforming expectations of wealth managers, who must now offer deeper advisory capabilities and a more modern, partnership-led approach.” Legal certainty has become a decisive factor for many families, particularly as the DIFC strengthens its jurisdiction over non-Muslim wills.
DIFC Wills and the New Era of Legal Certainty for Non-Muslims
Sandrine Reynaud, Co-founder and SEO, Freedom Asset Management, Middle East, says: “DIFC Wills are common-law wills that allow non-Muslims to specify how assets, both inside and outside the DIFC, should be distributed, effectively bypassing Sharia law. The recent changes, such as DIFC Law 2 of 2025, have given the DIFC exclusive jurisdiction over the enforcement of non-Muslim wills, increasing legal certainty.”
“It is a natural development in a complex environment where a majority of residents are foreign passport holders and nearly a quarter are non-Muslims. It makes the UAE more attractive for the increasing number of non-local family offices who are establishing in the UAE and it provides certainty for the residents who have already created a legacy in the region for a long time. This shows case the creativity, open-mind and flexibility of the UAE when it comes to creating an environment to attract capital and retain it there for the long term.”
Dubai Law No. 2 of 2025 explained. Dubai Law No. 2 of 2025 is a major development for private-wealth planning. The law gives the DIFC Courts primary jurisdiction over non-Muslim wills registered with the DIFC Wills Service and extends their authority to asset-ownership disputes involving DIFC-registered entities even when the underlying assets are located onshore in Dubai. This significantly strengthens legal certainty for expatriates by ensuring that a single, common law style forum can interpret and enforce their succession arrangements.
Taken together, these developments are influencing how global family offices position themselves in the region, with many now choosing the UAE as their primary base.
Why Global Family Offices Are Moving to the UAE
Andrew Horbury, Group Chief Executive Officer, Cavenwell Group, says: “We’re seeing a significant shift among international family offices that previously had no real connection to the Middle East. Many are now choosing the UAE, particularly the DIFC and ADGM, as the jurisdiction for their global family office. What’s driving this isn’t just the tax neutrality or lifestyle, it’s the depth and flexibility of the structuring toolkit that the UAE now provides.”
“Both centres offer modern foundation regimes that allow families to manage, control and consolidate overseas structures, such as those in Jersey, Cayman and BVI through a UAE-based governance layer. When paired with the Family Foundation Tax Election, families can centralise decision-making, investment governance and succession planning from the UAE while maintaining the tax neutrality, legal integrity and regulatory standing of their offshore entities.”
“A further development is the strengthening of the DIFC Courts’ jurisdiction. Dubai enacted Law No. 2 of 2025 earlier this year, giving the DIFC Courts primary jurisdiction over disputes concerning the ownership of assets held by DIFC entities, even when those assets are located on the Dubai mainland. This shift provides international families with a greater degree of predictability and comfort around asset protection and enforceability.”
“And while the dual system between onshore Sharia-based rules and common-law free zones can appear complex from the outside, in practice it is far more navigable than many assume. Once clients begin structuring here, they quickly see that clarity emerges by working with experienced advisers. We are fortunate to collaborate with several exceptional regional and international law firms who guide families through the appropriate pathway for their circumstances.”
“For me the direction of travel is clear, the UAE is becoming a global command centre for internationally mobile capital and family governance, not only for regional families but increasingly for European, Asian and Latin American UHNW families seeking institutional-grade structuring in a highly international environment.”
The Family Foundation Tax Election explained. The Family Foundation Tax Election is simply a choice that prevents a UAE family foundation from becoming a taxable entity, so families can use it to oversee their assets without creating an extra layer of UAE tax. As Horbury notes, tools such as the Family Foundation Tax Election, together with clearer court jurisdiction and modern foundation laws, are turning the UAE into a genuine command centre for global family wealth. For UHNW families the attraction is no longer just lifestyle or tax neutrality, but the ability to place wills, governance, holding structures and dispute resolution under one roof in a jurisdiction that international advisers increasingly regard as central to long-term estate planning.
Citywealth Forum
On the 12th May 2026, Citywealth will discuss conflicts in different laws at our Citywealth annual Forum, the day before the Citywealth Magic Circle Awards. Agenda here. The segment is called Crossroads of Sharia and Common Law, Jewish law and other religious legal conflicts. Unexpected pitfalls, from forced heirship conflicts to cross-border enforceability issues. We will also include halachic (Jewish law) and other religious laws.
Jonathan Burt’s Citywealth Leaders List profile
Charles Russell Speechlys’ Citywealth Leaders List profile
Alessandro Umberto Belluzzo’s Citywealth Leaders List profile
Belluzzo International Partners’ Citywealth Leaders List profile
Lombard Odier’s Citywealth Leaders List profile
Andrew Horbury’s Citywealth Leaders List profile
Cavenwell Group’s Citywealth Leaders List profile
Key takeaways and FAQ below
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Key Takeaways: UAE Wealth Structuring 2025: New Laws, Foundations, Wills and Global Family Office Trends
- The UAE Wealth Structuring 2025 article highlights new laws and courts enhancing private wealth planning for ultra-high-net-worth families.
- Dubai Law No. 2 of 2025 will allow non-Muslims to make wills under their own national laws, providing legal certainty and a modern framework.
- DIFC and ADGM are becoming key hubs for estate planning, reflecting growing demand for UAE-based governance amidst rising non-Muslim populations.
- Family structures are shifting, with more families using UAE foundations and trusts for succession planning and asset management.
- UAE now attracts global family offices seeking flexibility and institutional-grade structuring for wealth management.
Q. What does Dubai Law No. 2 of 2025 change for non-Muslim inheritance?
A.The law grants the DIFC Courts primary jurisdiction over non-Muslim wills registered with the DIFC Wills Service. It also allows the DIFC Courts to rule on disputes involving assets held by DIFC entities even if those assets are located onshore in Dubai. This gives expatriates a single, common law forum for succession matters.
A. Dubai Law No. 2 of 2025 is significant because it removes one of the biggest sources of uncertainty for expatriates. Previously, when a non-Muslim died owning assets in Dubai, there was always a possibility that a matter could move between the onshore courts and the DIFC Courts. Each operates under a different legal tradition. Onshore courts apply a civil law system influenced by Sharia principles, while the DIFC applies a common law system. Giving the DIFC Courts primary jurisdiction over non-Muslim wills brings clarity. Families know in advance which court will interpret the will, oversee probate and determine how assets should pass. This is particularly valuable where a family owns both UAE and overseas assets, or where the succession plan reflects common law concepts that do not exist in the onshore system. The new law also strengthens enforcement. The DIFC Courts can now rule on disputes involving assets held by DIFC entities even when those assets physically sit onshore in Dubai. As a result, families gain a single, predictable forum that understands international estate planning, recognises foreign law and is comfortable handling multi-jurisdictional estates.
For expatriates, the benefit is straightforward. A registered DIFC will is now more secure and more likely to be applied as intended. It gives reassurance that Dubai’s courts will follow the chosen succession plan rather than default inheritance rules. This is central to why the DIFC has become the preferred choice for non-Muslim wills in the UAE.
A. Yes, but their role is shifting. Many families retain offshore trusts and companies while establishing a UAE governance layer above them. Enforcement risk remains an important consideration, shown by the Almakhawi case in which a Jersey, Channel Islands court recognised a Dubai judgment that allowed a bank to reach assets held in a Jersey trust.
A. The court offers civil marriages and wills for non-Muslims and Muslim foreigners under a secular framework. It provides a clear, accessible process and has proved popular with internationally mobile families. It is becoming a significant onshore alternative to free-zone courts. It also offers fast divorce potentially aiming at a global centre for divorce.
A. Care is needed to ensure that assets are eligible to be placed into UAE foundations or companies. Regulatory restrictions, funding hurdles and cross-border conflicts can arise if structures are set up without full due diligence. Governance frameworks must also keep pace with asset growth to avoid frozen accounts or fragmented ownership.
A. Younger wealth creators want transparency, digital access and investment strategies that reflect their values. They are also prompting families to adopt more formal governance systems and clearer succession plans. Shariah-compliant and sustainable investments are growing in significance.
A. The UAE now offers a sophisticated toolkit that includes modern foundation regimes, tax elections for family foundations and stronger court jurisdiction. Together these create a predictable and internationally compatible base for managing global wealth. Many offshore structures, including those in Jersey, Channel islands, Cayman and the BVI, can be overseen from a single UAE platform.
Citywealth Weekly: 12th November 2025
Stay updated with Citywealth Weekly: 12th November 2025 for the latest insights and trends in wealth management.
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