Jurisdictions · Compare
Mauritius vs Dubai (DIFC) Family Office: Rules and Tax 2026
Our view
Both license the family office. Mauritius asks for USD 5 million in net assets under management at all times, DIFC for USD 50 million in family net assets, confirmed every year. Mauritius charges 15% company tax, with an 80% partial exemption on qualifying income, subject to substance, and its 10-year family office tax holiday is unconfirmed under the 2026 Rules. 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; Mauritius's Finance Act 2026 sets a 35% top rate. A family with USD 5 million to under USD 50 million can set up a single family office only in Mauritius of the two.
Key differences
- Minimum wealth: USD 50 million in family net assets, confirmed every year, in DIFC, against USD 5 million in net assets under management or administration, at all times, in Mauritius.
- Company tax: 9% above AED 375,000, with 0% only on qualifying income (not an unregulated family office's wealth and fund management income), in the UAE, against 15% in Mauritius, with an 80% partial exemption on qualifying income if substance conditions are met.
- Personal income tax: none in the UAE, against 0% to 35% in Mauritius, with 35% above MUR 12 million under the Finance Act 2026.
- Succession: non-Muslim wills registered with the DIFC Courts Wills Service in DIFC, against forced heirship in Mauritius, where Chambers reports that children reserve one half to three quarters of the estate.
- Residence: a 10-year Golden Visa from AED 2 million in the UAE, against a residence permit for at least USD 375,000 in residential property under EDB schemes, or a golden visa with a USD 1 million investment undertaking, in Mauritius.
- 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 processing fee and USD 4,000 a year for a single family office licence in Mauritius.
Side by side
| Topic | Dubai (DIFC) | Mauritius |
|---|---|---|
| Licence | Family Office licence from the DIFC Registrar; no DFSA licence | Family Office (Single) licence from the FSC under the 2026 Rules |
| Minimum wealth | USD 50 million in family net assets, confirmed every year | USD 5 million net assets under management or administration, at all times |
| 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 | Spouse, ancestors, descendants, siblings, in-laws, aunts, uncles, cousins, approved dependants |
| Serving several families | Registrar's approval to serve several families (USD 50 million each); a DFSA licence to give them financial services | Family Office (Multiple) licence: USD 25 million in total and USD 5 million per family |
| Law and courts | DIFC laws; English-language DIFC Courts | Code Civil Mauricien with forced heirship; Privy Council appeals (reported) reported |
| Substance | No minimum staff or spending rule found; 0% tax status needs adequate substance | No office or staff test in the 2026 Rules; approved agent; 80% exemption needs substance |
| Holding vehicles | Company, foundation, trust, prescribed company (SPV) | Companies (incl. Global Business Licence), sociétés, partnerships, trusts, foundations |
| Corporate tax | UAE corporate tax: 0% up to AED 375,000, 9% above | 15%; 80% partial exemption on qualifying income (effective 3%) with substance |
| Family office tax | 0% only on qualifying income, not unregulated wealth management; foundations can be transparent | 10-year tax holiday (FSC, EDB); office, staff, over USD 5 million; 2026 status unclear |
| Personal income tax | None | 0% to 35%; 35% above MUR 12 million from the income year ending June 2027 (EY) |
| Inheritance tax | None in the official UAE list of taxes | No inheritance, estate or gift tax, per Chambers (no official statement found) reported |
| Wills and succession | Non-Muslim wills registered with the DIFC Courts Wills Service | Forced heirship: children reserve 1/2 to 3/4 of the estate (reported) reported |
| Residence | 10-year Golden Visa from AED 2 million in property or investments | USD 375,000 property in EDB schemes; golden visa USD 1 million; Investor OP USD 100,000 |
| 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 | Single family office: USD 2,500 processing and USD 4,000 a year (FSC, July 2026) |
