European family offices and UAE property (2026): tax treaties country by country

European family offices weighing UAE property face a home country question before a UAE one: Switzerland, Italy, France and the Netherlands each have a double taxation agreement with the UAE, while Germany has had none since its 2010 agreement expired on 31 December 2021, according to Germany Trade and Invest on 19 April 2024. In the UAE itself, Cabinet Decision No. 49 of 2023, effective 1 June 2023, keeps an individual's unlicensed real estate investment income outside corporate tax, so for most European owners the tax on Dubai rent is the tax charged at home.

This guide is for a principal or family office in Germany, Switzerland, Italy, France or the Netherlands considering UAE property or a UAE base. For each country it sets out the treaty position, how foreign rental income is treated at home and the departure rules to check before relocating, each from the tax authority or the treaty text where we could read it. It then covers the UAE side: freehold ownership, holding structures, the Golden Visa, escrow and mortgages. It is not tax or legal advice. Every home country point should be confirmed with an adviser in that country.

Why are European family offices using the UAE as a second base?

The movement of wealth is measured, and the figures are dated. The Henley Private Wealth Migration Report 2025, as reported by Gulf News on 24 June 2025, projected a net inflow of 9,800 millionaires to the UAE in 2025, the highest of any country, and a net loss of 16,500 for the United Kingdom. Economy Middle East, reporting the same edition, gave the wealth moving with them as USD 63 billion and listed projected net outflows of 400 millionaires from Germany and 800 from France, against net gains of 3,000 for Switzerland and 3,600 for Italy. Those are projections for 2025, not counts.

For family offices specifically, the Financial Times reported on 3 May 2025, in an article republished by swissinfo.ch, that about 200 family offices had joined the DIFC in the previous year, bringing the total to 800. The same report cited Swiss advisers on families exploring a move because of regulation, privacy and the debate over a proposed 50 per cent Swiss tax on very large inheritances. An undated opinion article published by Economy Middle East estimated that the UAE hosts 75 per cent of Middle Eastern family offices.

The pattern in those reports is a second base rather than a clean break. A family keeps its home country holdings and adds a UAE entity, a UAE residence or UAE property. That is why the home country rules below matter as much as the UAE ones: they decide whether the UAE asset is taxed twice, once or, in effect, at home only.

Does Germany have a tax treaty with the UAE?

No. Germany and the UAE signed a double taxation agreement in Berlin on 1 July 2010, approved by a German federal law published on the Federal Ministry of Justice's legislation portal. EY reported on 15 July 2021 that the agreement would end on 31 December 2021 unless both states agreed to extend it, and that Germany had told the UAE on 14 June 2021 that it would not. Germany Trade and Invest, the federal economic development agency, wrote on 19 April 2024 that the agreement expired on 31 December 2021 and that there were no efforts to conclude a new one.

Some guides date the end of the German treaty to 2008. That refers to the first agreement, of 9 April 1995. The 2010 agreement replaced it and has itself expired, so the current position is that there is no treaty.

For a German resident, the consequence for rental income is direct. Germany Trade and Invest explains that Germany's unilateral relief, the credit under section 34c of the Income Tax Act, gives no relief in the UAE's case because the UAE levies no tax to credit. UAE rental income of a person with unlimited German tax liability is therefore taxed in Germany at the owner's personal rate.

For a German principal relocating to the UAE, the exit tax is the first pointer. PwC Germany wrote on 1 October 2026 that, since 1 January 2022, the German exit tax applies to shares in corporations of at least 1 per cent held at any time in the past five years, where the owner was subject to unlimited German tax liability for at least seven of the last twelve years. The tax falls due on departure, and on request can be paid in seven equal annual instalments, usually against security. Confirm the position with a German Steuerberater before moving.

How are Swiss investors in Dubai property taxed at home?

Switzerland and the UAE signed their agreement on 6 October 2011, and it entered into force on 21 October 2012 by exchange of notes, according to the Swiss Federal Tax Administration. Article 6 of the agreement provides that income a Swiss resident derives from immovable property in the UAE may be taxed in the UAE.

Article 22 then sets the Swiss method. Switzerland exempts that income from tax, but may apply the rate that would have applied without the exemption when it taxes the resident's other income. SWI swissinfo.ch, in a guide published on 13 February 2026, describes the same general rule: foreign property is not taxed in Switzerland but affects the tax rate. The UAE property and its income must still be declared on the Swiss return.

For a Swiss principal moving to the UAE, the same swissinfo.ch guide describes liability ending on the date of deregistration, income taxed to that date, assets valued at the end of the tax period and, in some cantons, taxes payable before departure. It does not describe a general exit tax on private assets. Swiss property kept after the move remains taxable in Switzerland. Confirm the cantonal treatment with a Swiss adviser.

What should an Italian family office in Dubai know about tax at home?

Italy and the UAE signed their convention in Abu Dhabi on 22 January 1995, and Italy ratified it by Law No. 309 of 28 August 1997, whose text has been in force since 19 September 1997 according to the official Normattiva database. The Normattiva page reproduces the ratifying law but not the full convention text, so we could not read the property article or the relief article there.

On the home side, an adviser's note published on Mondaq on 7 April 2026 says an Italian resident must declare and pay Italian tax on the net profit from rental income on property held overseas, added to other income and taxed at the IRPEF rate. The same note puts IVIE, the Italian tax on the value of property held abroad, at 1.06 per cent, assessed on the purchase value for property outside the European Union. A Dubai apartment bought for AED 3 million would therefore carry IVIE on that purchase value each year while its owner is Italian resident.

For an Italian family office, the practical point is that holding UAE property through a UAE vehicle does not by itself take the family outside Italian rules on foreign assets and foreign companies. We did not find an official Italian source we could read in full on departure taxation for individuals moving to the UAE, so this guide does not state one. Confirm residence and exit rules with an Italian commercialista before relocating.

How are French investors in Dubai real estate taxed?

The France UAE convention was signed on 19 July 1989, entered into force on 1 July 1990 and was amended by an avenant signed on 6 December 1993 that entered into force on 1 June 1995, according to the French tax administration's BOFiP commentary published on 12 September 2012.

Article 5 of the convention provides that income a resident of one state derives from immovable property is taxable in the state where the property is. Article 19 relieves French tax on income the convention allocates to the UAE with a credit equal to the corresponding French tax, which on our reading of the text covers rental income under Article 5. Gains are different. Article 11 lets the UAE tax gains on UAE property, but Article 19 relieves French tax on them only with a credit equal to the UAE tax paid, capped at the French tax. Where no UAE tax is paid on the gain, the credit gives little or no relief, so a French resident should model French tax on any sale.

For a French principal leaving for the UAE, the French tax authority's exit tax page, modified on 10 March 2026, says the tax applies to a person who was French tax resident for at least six of the ten years before the move and holds securities worth at least EUR 800,000 or at least 50 per cent of a company's profits. It covers unrealised gains on those holdings. Deferral rules for moves outside the European Economic Area are set out on the same page. Confirm the position with a French avocat fiscaliste before moving.

What do Dutch investors in Dubai property need to declare?

The Netherlands and the UAE signed their convention in Abu Dhabi on 8 May 2007, and it entered into force on 2 June 2010, according to Tractatenblad 2010, 178. The treaty text itself is published in Tractatenblad 2007, 107, which we could not read in full, so this guide does not state its property article or relief method.

On the home side, the Belastingdienst's 2025 return guide says real estate is declared in box 3 whether it is in the Netherlands or abroad, valued at market value, with a reduced percentage for let property only where the country has comparable tenant protection. The Belastingdienst's page on foreign income says a resident is entitled to relief from double taxation where a treaty gives the other country the right to tax, and that the relief means no Dutch tax on that foreign income. Whether and how that relief reaches a box 3 asset in the UAE depends on the treaty wording, which a Dutch belastingadviseur should confirm.

We did not find an official Dutch statement we could read in full on departure taxation for a substantial shareholder emigrating to the UAE, so this guide does not state one. Ask before moving.

How does a European family buy, hold and finance UAE property?

Ownership. Article 4 of Dubai Law No. 7 of 2006, issued on 13 March 2006, allows non UAE nationals, in areas the Ruler designates, freehold ownership without time limit, or usufruct and leasehold for up to 99 years. Nationality inside Europe makes no difference to that right.

Cost. The Dubai Land Department's sale registration page, updated on 3 November 2026, lists a transfer fee of 2 per cent from the seller and 2 per cent from the buyer, a title deed fee of AED 250 and a service partner fee of AED 4,000 plus VAT for sales of AED 500,000 or more.

Structure. A family can hold title personally, through a company or through a foundation. The Land Department's company registration page says foreign companies must be registered in a free zone in Dubai or Ras Al Khaimah, and free zone buyers need a no objection certificate from their licensing authority. A European company cannot simply buy in its own name. Our guides to holding UAE property personally, through a company or a foundation and to setting up a family office in the DIFC or ADGM set out the vehicles, the thresholds and the corporate tax position. A UAE company that owns property is a taxable person, and how the home country treats a UAE company owned by its residents should be checked at home.

Residency. The Land Department's Golden Visa page, updated on 3 November 2026, requires property with a purchase value of at least AED 2 million, wholly owned in the applicant's name, and describes a 10 year renewable permit; a mortgaged property needs a bank letter. The federal u.ae page, updated on 28 July 2026, lists 5 years for real estate investors. ICP, the federal authority that issues the permit, settles the point: its Golden Residency guide, updated on 10 September 2026, gives 10 years for investors in the real estate sector. The two official pages differ, so ask the issuing authority. Property held in a company or foundation is not addressed on the Land Department page. See our Golden Visa page.

Off plan. Article 6 of Law No. 8 of 2007, issued on 6 May 2007, requires a developer to request an escrow account before selling off plan, Article 7 requires buyers' payments to go into it, Article 9 requires a separate account for each project, and Article 14 requires 5 per cent to be retained for a year after units are registered to buyers.

Finance. The Central Bank of the UAE's mortgage regulation sets loan to value limits for nationals and expatriates and does not mention non residents, so each bank sets its own terms. HSBC UAE's non resident page, read on 7 November 2026, offers up to 60 per cent of the property's value to Premier and Private Bank customers. The dirham is fixed against the US dollar under the Central Bank's framework, so a buyer funding in euros or Swiss francs carries exchange rate exposure against the dollar. Our mortgages page sets out the bank options.

What it means for investors

The treaty map divides the five countries in two. A Swiss resident's UAE rental income is exempt at home under Article 22 of the Swiss agreement, subject to the rate effect, and on our reading a French resident's is relieved by a credit equal to the French tax under Article 19 of the French convention, a point to confirm with a French adviser. A German resident has no treaty and pays German tax on the rental income. Italian and Dutch residents have treaties, but their home rules on foreign rent and foreign assets, including Italy's IVIE at 1.06 per cent and the Dutch box 3 charge, can make the UAE asset part of the annual home tax calculation whatever the treaty says about rent.

Gains need separate modelling. Under the French convention, relief on a gain is limited to the UAE tax paid, and where that is nothing, French tax on the gain remains. A German or Dutch owner should also ask how a sale is taxed at home before setting an exit plan.

Relocation changes the picture more than the purchase does. A German principal with a 1 per cent shareholding and seven years of residence in the last twelve faces exit tax on leaving, and a French principal with securities of EUR 800,000 or more and six years in the last ten faces the same question. The UAE property decision should follow the residence decision, not lead it.

On the UAE side the rules are the same for every European buyer: freehold in designated areas, a 4 per cent transfer fee, escrow for off plan purchases, AED 2 million for the property route to a Golden Visa, and non resident mortgages on each bank's own terms. The variable is the home country, which is why the structure should be designed with both sets of advisers at the table.

What we recommend

1. Start with residence. Decide whether the family is buying an asset from home or moving its base, because the exit tax rules in Germany and France, and the departure rules in Switzerland, Italy and the Netherlands, apply only on a move.
2. Ask a home country adviser three questions before signing: how UAE rent is taxed, how a UAE sale is taxed, and how a UAE company or foundation would be treated.
3. If you are German, model full German tax on the rent; there is no treaty to rely on. If you are French, model French tax on the gain.
4. If residency depends on property, keep at least AED 2 million of property in the applicant's own name, or confirm with the issuing authority before using a structure.
5. Confirm with the Land Department that any company or foundation can register title before forming it.
6. If you are borrowing, confirm with the bank that it lends to non residents of your country, and on what loan to value, before committing to a price.
7. Confirm the current position with the authority before relying on it. Treaty texts, home country rules and UAE procedures change, and several points in this guide rest on official pages dated between 2012 and November 2026.

Castilion Estates works with European principals on the asset side and coordinates the UAE lawyers and corporate service providers who build the structure, through our cross border investment advisory. Castilion Estates does not give tax or legal advice, and every home country question in this guide belongs with your own adviser.