Expanded Tax Transparency for Holding Companies within UAE Family Foundations

Before Ministerial Decision No. (261) of 2024, underlying holding companies of a UAE foundation were not eligible for the same tax transparency treatment as the UAE foundation itself.

With the introduction of Decision No. (261), any holding company or special purpose vehicle (SPV) wholly owned and controlled by a UAE family foundation (‘foundation’) can now apply for the same tax-transparent treatment as the ultimate UAE family foundation.