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

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There is no equivalent to a Foundation registered with the Dubai International Financial Centre (DIFC) Registrar of Companies under English law. Broadly, a Foundation may be treated as a trust, a bare trust or a company for UK tax purposes. Two key factors in determining this are whether the Foundation holds assets for itself beneficially, and, if held for others, whether those others are absolutely entitled to the assets. The treatment of a DIFC Foundation depends on how the Foundation is categorised, as well the settlor’s domicile and residence and the Foundation’s residence. Proposed changes to taxation of non-domiciled individuals should be considered by individuals when using Foundations.

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