Bengaluru and Dubai, run by the same firm: structuring for families and businesses with real activity on both sides of the India-Gulf corridor, not a single-jurisdiction view of a genuinely two-sided situation.
DIFC and ADGM vehicles versus Indian trusts
The Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) both offer foundation structures purpose-built for wealth holding and succession — common-law-based, English-language, with their own courts. For a family whose wealth genuinely centres on Gulf-held assets, a DIFC or ADGM foundation is often the cleaner vehicle; for a family whose wealth centres on Indian assets, an Indian private trust remains the natural default (see our Structure & Vehicle page for the full India-side scoring). Most families operating across this corridor run both, deliberately coordinated rather than picked as alternatives.
UAE residency and the 2023 corporate tax
The UAE has no personal income tax, which remains the headline reason families and individuals structure through it. Since 2023, UAE-incorporated entities face a 9% corporate tax on profits above a threshold — a real change, but the UAE remains materially lower-tax than India for corporate structures, and qualifying free-zone entities can still access a 0% rate on qualifying income if the structuring is done correctly from the outset, not assumed to carry over unchanged from before 2023.
The India-UAE DTAA
The Double Taxation Avoidance Agreement between India and the UAE determines which country taxes what when a family or individual has genuine ties to both — but relief under it has to be claimed, not assumed: a Tax Residency Certificate from the UAE side plus Form 10F filed in India, the same documentation discipline any DTAA claim requires.
Saudi Arabia: a related but distinct regime
Saudi Arabia runs its own, separate set of rules for foreign ownership, including real estate — covered directly in our Saudi real estate ownership guide. It shouldn't be treated as interchangeable with UAE structuring just because both sit in the wider Gulf.
Common questions
Is a DIFC or ADGM foundation always better than an Indian trust for a family with Gulf ties?
Not always — it depends on where the family's economic activity and eventual beneficiaries actually sit. A foundation makes sense when the family's wealth genuinely centres on Gulf-held assets; an Indian trust makes sense when it centres on Indian assets and succession. Most families we work with across this corridor end up with both, structured to talk to each other rather than compete.
Does the UAE's 9% corporate tax change how an India-linked business should be structured there?
It changes the calculation, not the logic — the UAE remains a materially lower corporate-tax jurisdiction than India, and free-zone entities can still qualify for a 0% rate on qualifying income if structured correctly from the outset. It just means the structuring has to be done properly, not assumed to still work exactly as it did before 2023.
Can DTAA relief between India and the UAE be assumed automatically?
No — it has to be claimed, typically with a Tax Residency Certificate from the UAE side plus Form 10F filed in India, the same requirement that applies to every DTAA claim. It isn't automatic just because the treaty exists.
See the full cross-border tax framework on our Family Office hub →