Jurisdictions · Compare
Dubai (DIFC) vs India (GIFT City) Family Office (2026)
Our view
DIFC licenses the family office and asks for USD 50 million in family net assets, confirmed every year. In GIFT City the family registers its own fund manager with IFSCA to run a Family Investment Fund for one family, with no family wealth test but a USD 10 million corpus within 3 years. IFSC units can deduct 100% of income from approved business for 20 of 25 years, but no source confirms a family fund's income qualifies. UAE corporate tax is 9% above AED 375,000, with 0% only on qualifying income, and the FTA says an unregulated family office's wealth and fund management income does not qualify. The UAE has no personal income tax; India's top rate is 30% plus surcharge and cess. Families wanting their fund inside India will look at GIFT City.
Key differences
- Structure: a family office company licensed by the DIFC Registrar in DIFC, against a Family Investment Fund run by the family's own fund manager, registered with IFSCA, in GIFT City.
- Minimum: USD 50 million in family net assets, confirmed every year, in DIFC, against no family wealth test but a fund corpus of USD 10 million within 3 years in GIFT City.
- Business tax: 9% UAE corporate tax above AED 375,000, with 0% only on qualifying income (not an unregulated family office's wealth and fund management income), in DIFC, against a 100% deduction of an IFSC unit's income from approved business for 20 of 25 years in GIFT City, where no source confirms that a family fund's income qualifies; otherwise company tax is 25% or 30% (22% by option) plus surcharge and 4% cess, and IFSC units earning only in foreign currency pay 9% minimum alternate tax.
- Personal income tax: none in the UAE, against a top rate of 30% above INR 2.4 million, plus surcharge and 4% cess, in India.
- Residence: a 10-year Golden Visa from AED 2 million in the UAE, against no residence route linked to GIFT City found in official sources.
- Fees: a USD 12,000 Family Office Licence fee under DIFC's 2023 rules (which do not say whether it is yearly), plus company fees, in DIFC, against a USD 2,500 application fee and USD 15,000 registration fee for a Family Investment Fund, then USD 3,000 a year for the fund manager's registration, in GIFT City.
Side by side
| Topic | Dubai (DIFC) | India (GIFT City) |
|---|---|---|
| Licence | Family Office licence from the DIFC Registrar; no DFSA licence | Family's own FME registered with IFSCA as an Authorised FME (2025 rules) |
| Minimum wealth | USD 50 million in family net assets, confirmed every year | No family wealth test; fund corpus of USD 10 million within 3 years (IFSCA FAQs) |
| Who counts as family | A living ancestor and their descendants, or descendants of an ancestor up to three generations back, with spouses, stepchildren and adopted children | Lineal descendants of a common ancestor, spouses, children and family-controlled entities |
| Serving several families | Registrar's approval to serve several families (USD 50 million each); a DFSA licence to give them financial services | Registered FME (Non-Retail) giving portfolio management to multi-family offices |
| Law and courts | DIFC laws; English-language DIFC Courts | Indian law; IFSCA as unified regulator; no separate IFSC courts found |
| Substance | No minimum staff or spending rule found; 0% tax status needs adequate substance | Principal officer based in IFSC and a dedicated, secured office |
| Holding vehicles | Company, foundation, trust, prescribed company (SPV) | Fund as company, contributory trust or LLP; FME as company, LLP or branch |
| Corporate tax | UAE corporate tax: 0% up to AED 375,000, 9% above | 25% or 30% (22% by option) plus surcharge and 4% cess (assessment year 2026-27) |
| Family office tax | 0% only on qualifying income, not unregulated wealth management; foundations can be transparent | No family office regime; IFSC units deduct 100% of approved income for 20 of 25 years |
| Personal income tax | None | 30% top rate above INR 2.4 million (new regime); surcharge up to 25% and 4% cess |
| Inheritance tax | None in the official UAE list of taxes | No estate duty (abolished 1985); gifts over INR 50,000 taxed as income, relatives exempt |
| Wills and succession | Non-Muslim wills registered with the DIFC Courts Wills Service | Depends on religion: Hindu Succession Act 1956 or Indian Succession Act 1925 (not Muslims) |
| Residence | 10-year Golden Visa from AED 2 million in property or investments | No official figure found |
| Time to set up | No official figure found | No official figure found |
| Official fees | USD 12,000 Family Office Licence under the 2023 rules (may be yearly), plus company fees | USD 2,500 application and USD 15,000 registration, then USD 3,000 a year (2026) |
