Jurisdictions · Compare
Dubai (DIFC) vs Saudi Arabia Family Office Compared (2026)
Our view
DIFC has a dedicated route: a Family Office licence from the DIFC Registrar for families with at least USD 50 million, with DIFC laws and courts, trusts, foundations and non-Muslim wills. No family office licence, wealth minimum or family definition was found in Saudi Arabia, where the office is an ordinary company that may adopt a family charter. Saudi and GCC owners pay zakat at 2.5% of the zakat base, and foreign-owned shares pay 20% income tax. 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. Saudi inheritance follows Sharia shares. The Saudi route fits Saudi and GCC families with businesses and assets in the Kingdom.
Key differences
- Family office licence: a Family Office licence from the DIFC Registrar in DIFC, against no family office licence or regime found in Saudi Arabia, where the office is an ordinary Companies Law company.
- Minimum wealth: USD 50 million in family net assets, confirmed every year, in DIFC, against no official figure found in Saudi Arabia.
- 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 20% income tax on foreign-owned shares and zakat at 2.5% of the zakat base on Saudi and GCC shares in Saudi Arabia.
- Personal and inheritance tax: no income tax on individuals and no inheritance tax in the official list of taxes in the UAE, against no individual income tax scheme and no inheritance, estate or gift taxes in Saudi Arabia, as reported by PwC.
- Succession: non-Muslim wills registered with the DIFC Courts Wills Service in DIFC, against Sharia shares under the 2022 Family Law in Saudi Arabia, where a will above one third of the estate needs the heirs' approval.
- Residence: a 10-year Golden Visa from AED 2 million in property or investments in the UAE, against Premium Residency in Saudi Arabia, whose investor and property routes are reported to need SAR 7 million invested and 10 jobs, or SAR 4 million in property.
Side by side
| Topic | Dubai (DIFC) | Saudi Arabia |
|---|---|---|
| Licence | Family Office licence from the DIFC Registrar; no DFSA licence | No family office licence found; a Companies Law company, with a CMA group exclusion |
| Minimum wealth | USD 50 million in family net assets, confirmed every year | No official figure found |
| 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 | No official figure found |
| Serving several families | Registrar's approval to serve several families (USD 50 million each); a DFSA licence to give them financial services | CMA authorisation to manage, advise or arrange for others by way of business |
| Law and courts | DIFC laws; English-language DIFC Courts | Companies Law, Family Law, Sharia where it is silent; commercial and personal status courts |
| Substance | No minimum staff or spending rule found; 0% tax status needs adequate substance | No family office rule found; RHQs need a local office, senior staff and an ESR filing |
| Holding vehicles | Company, foundation, trust, prescribed company (SPV) | Joint stock, simplified joint stock, LLC, partnerships, CMA funds, waqf; no trust law found |
| Corporate tax | UAE corporate tax: 0% up to AED 375,000, 9% above | 20% income tax on foreign-owned shares; 2.5% zakat on Saudi and GCC shares (2026) |
| Family office tax | 0% only on qualifying income, not unregulated wealth management; foundations can be transparent | No family office regime found; licensed RHQs pay 0% on eligible RHQ income for 30 years |
| Personal income tax | None | No individual income tax scheme; employment income not taxed (reported by PwC, 2026) reported |
| Inheritance tax | None in the official UAE list of taxes | None reported by PwC (2026); real estate passing to heirs exempt from 5% RETT reported |
| Wills and succession | Non-Muslim wills registered with the DIFC Courts Wills Service | Sharia shares under the 2022 Family Law; wills above one third need heirs' approval |
| Residence | 10-year Golden Visa from AED 2 million in property or investments | Premium Residency: SAR 7 million and 10 jobs, or SAR 4 million property (reported) reported |
| Time to set up | No official figure found | 10 working days for MISA investment registration; company registration time not found |
| Official fees | USD 12,000 Family Office Licence under the 2023 rules (may be yearly), plus company fees | No official figure found |
