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What is the UK tax treatment of Dubai (DIFC) Foundations?

There is no equivalent to a Foundation registered with the Dubai International Finance Centre Registrar of Companies under English law. How then should they be treated for UK tax purposes? Kyra Motley and Will Timbrell (Boodle Hatfield) investigate.

This article considers the characteristics and typical UK tax treatment of Foundations registered with the Dubai International Financial Centre (DIFC) Registrar of Companies. References to Foundations means DIFC Foundations. Definitively classifying a Foundation is difficult because it is not a vehicle recognised under English law. In broad terms a Foundation may be treated as a trust a bare trust or a company for UK tax purposes.

Foundations under DIFC law

DIFC law has been drafted to create a hybrid between a trust and a company. For UK taxation it is difficult to classify a Foundation as one or the other. As it is a new entity there...

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