Single-family office redomiciled from London to Dubai
A UK-based family losing the old non-dom tax treatment after April 2025, who needed a family office that genuinely operates in the UAE while their European property kept earning.
The situation
The head of the family had used the UK remittance basis (the non-dom treatment) for over ten years. It was being abolished from 6 April 2025, along with the protections that had shielded their offshore trust. They wanted a permanent base in the UAE, with a family office that actually ran from there, without disturbing the European property that brought in their income.
- The UAE presence had to be real: people, an office and decisions made there, not a licence and a mailbox.
- The European property had to keep running through the change, without breaching any loan terms.
- The existing offshore trust needed checking against the UK's post-April-2025 rules, not just moving as it was.
- Bank accounts had to be set up again in two banking centres before the move was complete.
Passing wealth on sits in the foundation, day-to-day running in the DIFC company, and the European property stays in a Luxembourg layer the lenders already know.
- Rental income
- European rent stays in the Luxembourg companies and is only paid up when it's needed.
- Family costs
- Paid from the UAE holding company, which receives dividends with no UAE tax kept back.
- Governance
- Investment and payout decisions made and minuted by the DIFC board — which is what makes the UAE presence real.
What we did, step by step
- 01UK exit analysis first
Worked out the family head's position under the new four-year foreign income and gains (FIG) regime, and the loss of trust protections, before setting anything up.
- 02Foundation established
Set up a DIFC Foundation with a council, a guardian and a charter that reflects how the family actually makes decisions, not a template.
- 03Family office licensed and staffed
Licensed the DIFC company, leased an office and hired three local staff, so the presence existed before anyone needed to rely on it.
- 04European assets re-layered
Put two Luxembourg companies above the property companies, agreed with the lenders in advance so no loan terms were breached.
- 05Banking migrated
Opened accounts at two private banks using one source-of-wealth file prepared once and reused; both accepted it first time.
- 06Old trust dealt with deliberately
Reviewed it rather than just closing it; rebuilt the payout policy and reporting for the post-2025 rules.
- The DIFC family office was running with real staff and an office before the family head's UAE residence began.
- European rental income carried on without a break; no loan terms breached during the reorganisation.
- Two private banking relationships opened in the intended banking centres within the moving window.
- The remaining UK tax exposure after April 2025 worked out and documented, rather than discovered later.
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