Setting up a UAE family office for real estate: DIFC, ADGM, foundations, residency

A family that wants a UAE base for its wealth has two financial centres to choose from and a third, lighter option for holding assets. The DIFC licenses family offices under the Family Arrangements Regulations 2023, with a minimum family net asset value of USD 50 million. ADGM lists a single family office threshold of USD 10 million on its family office page, published on 26 August 2024. Property is then usually held by a foundation or holding company in the DIFC, ADGM or RAK ICC, registered with the Dubai Land Department.

This guide is for principals and their advisers in Europe, the Americas, Asia, Africa and the Gulf who are deciding where to put a family office and how it should own UAE real estate. It sets out what each vehicle requires, whether it can register Dubai freehold title, how it is taxed and how the family obtains residency. It is not legal or tax advice. Every structure described here is built by licensed corporate service providers and counsel, and each point should be confirmed with them and with the authority concerned.

What are the options for a family office in the UAE?

There are three layers to think about, and families often use all three. The first is the family office itself: the entity that employs staff, keeps the family's records and manages its affairs. The second is the holding vehicle: a foundation or company that owns the assets. The third is the property itself, registered in the name of the holding vehicle or of a special purpose company beneath it.

The DIFC in Dubai and ADGM in Abu Dhabi both offer a licensed family office and foundations. RAK ICC, the international corporate registry in Ras Al Khaimah, offers companies and foundations for holding assets but not a regulated family office regime of the same kind. Onshore, the Dubai Centre for Family Businesses was launched under Dubai Chambers in May 2023, according to Dubai Chambers, to support governance and succession in family businesses. Its first sessions covered Federal Decree Law No. 37 of 2022 on family companies and Dubai Law No. 9 of 2020 on family ownership, the two laws that govern family owned trading companies outside the financial centres.

What does a DIFC single family office require?

The DIFC regime is set out in the Family Arrangements Regulations 2023, which came into force on 31 January 2023 and repealed the Single Family Office Regulations of 27 December 2011. Under the new regulations a Family Office is a registered person licensed as such by the DIFC Registrar of Companies.

The central test is money. Regulation 4.1.2 requires the family to meet the Minimum Net Asset Requirement, defined as an aggregate net asset value of USD 50,000,000 determined by a fair market value assessment, or a book value assessment where fair market value cannot be ascertained. Squire Patton Boggs noted in March 2025 that the former regulations required investable or liquid assets above USD 10 million, and that the grace period for existing offices to comply expired on 31 January 2024.

The regulations define a family as two or more family members descended from a common ancestor identified to the Registrar, together with spouses, stepchildren and adopted children. The common ancestor may be no more than three generations back at the time of registration. A Family Office serves one family, and serving more than one needs the Registrar's approval.

The application is made on the Registrar's form, with a statement of the family's details or a letter from a corporate service provider confirming them. Al Tamimi and Company, in an article edited on 2 April 2026, said the statement covers the family's structure, source of wealth and funds, control arrangements and beneficial ownership. The regulations set the Family Office Licence fee at USD 12,000.

Two further features matter to a property holding family. A family can enter its businesses on the DIFC Family Business Register, for a fee of USD 5,000. And a Family Office or Family Entity can apply to keep its shareholders, directors and officers on a Private Register that is not disclosed on the public register, for a fee of USD 1,000.

What does ADGM offer a family office?

ADGM's family office page, published on 26 August 2024 and accessed on 7 November 2026, describes a single family office as "a company established to exclusively manage the financial and personal affairs of one wealthy family". It lists minimum family net assets of USD 10 million, an incorporation fee of USD 5,600 and an annual renewal of USD 5,300, with no minimum capital or bank balance.

According to the same page, a single family office does not need a financial services permission but is a controlled licence activity, and a business plan is submitted before the online application. It can register as a Restricted Scope Company, which limits public disclosure to the company's name and office address. A multi family office serving several families is regulated by the Financial Services Regulatory Authority under a Category 4 licence, with fees of USD 16,800 to incorporate and USD 16,500 a year.

The published threshold should be checked before planning around it. Squire Patton Boggs wrote in March 2025 that ADGM had no minimum liquid or net asset requirement, which does not match the USD 10 million figure on ADGM's own page. The ADGM Registrar is the authority to confirm the current rule.

What is a foundation, and why do families use one to hold property?

A foundation is an entity with its own legal personality that owns assets for purposes or beneficiaries set out in its charter and by laws. It has no shareholders. It sits between a company and a trust: like a company it can contract and hold title in its own name, and like a trust it exists to benefit others.

In the DIFC, foundations are governed by DIFC Law No. 3 of 2018, the Foundations Law, consolidated in March 2024. Article 10 says a foundation is a body corporate with a legal personality separate from its founders, and that its property is not held on trust for anyone. Article 22 requires a council of at least two members to administer the property, and Article 23 requires a guardian where the foundation has a charitable or specified non charitable object. Article 29 provides that a beneficiary has no right to or interest in the foundation's property until a distribution is made.

In ADGM, foundations are governed by the Foundations Regulations 2017, enacted on 14 August 2017. Section 3 gives a registered foundation separate legal personality, section 15 says its assets "may comprise any property", and section 19 requires a council of at least two councillors. Under section 26, a guardian must be appointed when there is no surviving founder. ADGM's overview of the regime describes a foundation as a way to consolidate family holdings "into a single top holding entity". ADGM lists a foundation's incorporation fee at USD 1,000 and its annual renewal at USD 500.

Families use foundations for property for three reasons that follow from those provisions. First, continuity: because the foundation owns the title deed, the death of a founder does not put the property through probate in the way a personal title would, and the council continues to act. Second, protection against foreign heirship claims: Articles 14 to 16 of the DIFC law and section 32 of the ADGM regulations say a transfer into a foundation is not void or voidable because of a foreign forced heirship rule. Third, privacy: the DIFC law keeps the nationality and address of individuals off the public register, and ADGM describes its register as showing no individuals' names.

Can RAK ICC be used as a holding vehicle?

RAK ICC registers international companies and foundations in Ras Al Khaimah. Its foundations page, accessed on 7 November 2026, describes the RAK ICC Foundations Regulations 2019, as amended in 2025, a minimum capital of USD 100, a council of at least two members and an optional guardian. The page lists real estate among the assets a foundation can hold, "subject to local land registry requirements".

That qualification is the important one. A RAK ICC entity is a registry vehicle, not a licensed family office, and whether it can hold property depends on each emirate's land registry. RAK ICC's press releases record a memorandum with the Ras Al Khaimah Municipality Department, dated 6 April 2021, on international investors registering property in Ras Al Khaimah through RAK ICC entities. For Dubai, see the next section.

Can these vehicles own Dubai freehold property and register it with the DLD?

Yes, within limits, and the Land Department decides each case. Ownership by non UAE nationals is confined to the areas designated for foreign ownership, and a company or foundation must be registered with the Land Department before it can buy.

The Land Department's request to register companies page, updated on 3 November 2026, sets the current rules for companies. It accepts mainland companies, and free zone companies holding a licence or certificate of incorporation, which also need a no objection certificate from their licensing authority to buy property. It states that foreign companies must be registered in a free zone in Dubai or Ras Al Khaimah. The registration fee is AED 2,000 for a limited liability company and AED 4,000 for a company with foreign shareholders.

For DIFC vehicles, Al Tamimi and Company reported in May 2019 that the DIFC had announced a memorandum of understanding with the Land Department on 4 May 2018, and that DIFC foundations may own real estate in the areas designated for foreign ownership. The foundation needs a no objection certificate from the DIFC Registrar confirming its interest holders, its good standing and that its constitution permits it to own real estate. A report published by Chambers and Partners on 26 May 2019 said DIFC trusts that are not regulated as funds, and DIFC special purpose companies, were outside the arrangement, and that the Land Department was not then registering property for ADGM foundations.

For RAK ICC, Sovereign Group reported on 31 July 2019 that RAK ICC and RAKEZ had signed memoranda with the Land Department on 16 July 2019 allowing companies with individual shareholders to own property in Dubai's freehold areas, on a no objection letter from RAK ICC, and that the Land Department could reject an application that did not meet its rules.

Moving property already owned into a structure costs money. The Land Department charges 4 per cent on a sale, and Al Tamimi and Company wrote in May 2019 that a founder's transfer of personal property to their own DIFC foundation may be treated as a gift at a reduced 0.125 per cent, at the Department's discretion. Our guide to buying a whole building in Dubai sets out the fee rules and share transfers in more detail.

The 2019 reports are the most recent detailed public accounts we found, and Land Department practice has changed since. The vehicle, the area and the fee treatment should be confirmed with the Land Department before the structure is formed.

How are family offices, foundations and property income taxed?

Federal Decree Law No. 47 of 2022, issued on 3 October 2022, introduced UAE corporate tax. Cabinet Decision No. 116 of 2022, issued on 30 December 2022, sets the rate at 0 per cent on taxable income up to AED 375,000 and 9 per cent above it. A company that owns and lets property is taxed on its profit, subject to any relief that applies.

Two provisions of the law matter to family structures. Article 17 lets a family foundation apply to be treated as an unincorporated partnership, meaning tax transparent, if it is established for identified or identifiable natural persons, a public benefit entity or both, its main activity is holding and investing assets, it does not carry on activities that would be a business if its founder or beneficiaries carried them on directly, and avoiding tax is not its main purpose. Article 10 lets an investment fund apply to be a Qualifying Investment Fund, which is exempt, where the fund or its manager is regulated and its interests are listed or widely marketed.

The Federal Tax Authority updated its Corporate Tax Guide on the Taxation of Family Foundations on 10 June 2026, Baker McKenzie reported on 17 June 2026. According to that report, the guide says a natural person's transfer of personal or real estate investments to fund a family foundation should generally not be subject to corporate tax, and single and multi family offices are unlikely to meet the Article 17 conditions because they provide services. Al Tamimi and Company wrote on 23 June 2026 that a family office will generally be taxed at 9 per cent on its taxable income, and that services it provides to the family must be priced at arm's length.

These are high level points. The tax result depends on who owns the vehicle, what it does and where the family is tax resident, so every structure needs advice from a licensed UAE tax adviser and from the family's home country advisers.

How do principals obtain UAE residency?

The family office and its structures do not by themselves give the principal residency. The usual routes are the Golden Visa, an employment visa through the family office, or a visa linked to a licensed company.

The Dubai Land Department's Golden Visa investor service, updated on 3 November 2026, requires property with a purchase value of at least AED 2 million at the time of purchase, wholly owned by the investor in the applicant's name, and describes a 10 year renewable permit. A mortgaged property is accepted with a no objection letter from the bank. The federal u.ae Golden Visa page, updated on 28 July 2026, lists investors at 10 years for public investments and 5 years for real estate investments, with minimum capital of AED 2 million and the ability to sponsor spouses and children. 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 do not state the same term for property investors, so ask the issuing authority which applies.

There is a structuring point here. The Land Department's Golden Visa page refers to property in the applicant's own name and does not address property owned by a company or foundation. A principal who relies on property for residency should confirm the position before moving title into a structure. Our Golden Visa page sets out the property routes in more detail.

What it means for investors

The choice of centre is mostly a choice of threshold and home base. A family with net assets above USD 50 million can license an office in the DIFC, beside the Dubai freehold market. A smaller family can use ADGM's single family office, listed at USD 10 million, and both centres offer foundations for the assets themselves.

For property, the holding vehicle matters more than the family office. A DIFC foundation has a published route to Dubai title through the 2018 memorandum, a RAK ICC company has one through the 2019 memoranda, and every company needs Land Department registration under rules that were updated as recently as 3 November 2026. The register entry is what protects the family, so the vehicle should be accepted by the Land Department before it is formed.

For a family in the Americas, the UAE offers dollar based wealth a currency pegged to the US dollar and a common law court system in each financial centre. The reporting obligations at home are a separate matter. A United States or Canadian family that owns a UAE foundation or company will usually have reporting duties in its home country, and Latin American families face their own rules, so the home country adviser should see the structure before it is formed. European, Asian and African families face the same question under their own tax systems.

Castilion Estates works with family offices on the asset side. We source income producing assets, whole buildings and plots, many of which trade off market and are shared only under a signed NCNDA, through our commercial desk. Our cross border investment advisory looks at currency, structure and the tax interface before the first offer, and our asset protection and structuring service coordinates the lawyers and corporate service providers who build the vehicles. We do not give legal or tax advice.

What we recommend

1. Decide where the principal will live and where the assets will sit before choosing between the DIFC and ADGM, because that drives the courts, the advisers and the threshold.
2. Confirm the family's eligibility in writing. The DIFC requires USD 50 million in net assets under the Family Arrangements Regulations 2023, and ADGM's published USD 10 million threshold should be confirmed with its Registrar.
3. Confirm with the Dubai Land Department that the chosen foundation or company can register title in the area you are buying, and what fee applies to any transfer into it. Confirm the current position with the authority before relying on it.
4. Take UAE and home country tax advice on the whole structure, including whether a foundation should apply for transparency under Article 17.
5. If residency depends on property, confirm with the issuing authority whether property held in a structure counts before transferring title.
6. Appoint a licensed corporate service provider and UAE counsel to form the vehicles, and keep the property search separate from the legal work.

To discuss a family office mandate in confidence, contact the team.