Article 17 of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses and its amendments ("Corporate Tax Law") and Article 5 of Ministerial Decision No. 261 of 2024, provide for the treatment of family wealth management structures for Corporate Tax purposes.
The purpose of this Public Clarification is to provide clarity on the Corporate Tax implications of family wealth management structures, including a Single Family Office ("SFO") or a Multi Family Office ("MFO").
A family wealth management structure typically includes the following entities:
- a Family Foundation,
- a holding company,
- a Special Purpose Vehicle ("SPV"),
- a SFO or MFO, and
- family members.
The Corporate Tax treatment of these entities and the family members is considered in turn below, after which four examples of typical structures are set out.
A Family Foundation means any foundation, trust or similar entity, whether domestic or foreign, that meets the conditions of Article 17(1) of the Corporate Tax Law. For the...