Opinion

From offshore to onshore: How DIFC Foundations are changing family investment structures

For many years, families investing internationally defaulted to offshore holding structures. Companies and trusts were often established in familiar jurisdictions even when assets and decision-making sat elsewhere. That approach is now being questioned, particularly by families with growing exposure to Dubai.

In recent years, DIFC Foundations have moved steadily into that space. What was once used selectively has become part of how families organise ownership and control within the UAE, especially where assets and family life are now based locally.

This article examines why that change is taking place, how DIFC Foundations are being used in practice, and what this says about the way family investment structures are evolving in Dubai.

A clear increase in DIFC Foundation usage

Since around 2020, the number of DIFC Foundations used by private families has increased steadily. Foundations that were once the exception are now appearing regularly in structures holding UAE real estate, operating companies and investment portfolios connected to the region.

Earlier foundations were often set up for a narrow purpose, such as holding a flagship property or a single family investment company. More recent structures look different. It has become common for one DIFC Foundation to sit above multiple asset classes, including local property, foreign subsidiaries and liquid investment accounts.

As foundations have been used more often, things have become easier. Banks tend to engage more quickly, questions around control are clearer, and administration usually runs smoothly.

Why offshore structures are being revisited

Offshore companies and trusts are still widely used, but their drawbacks are being felt more acutely. One issue is distance. When a holding structure sits in a jurisdiction with little connection to where assets are managed, simple actions can take weeks rather than days.

Another issue is scrutiny. Banks and counterparties now look more closely at where control sits and where decisions are made. Structures that lack a clear link between the family’s place of residence and the location of the vehicle often prompt additional questions.

Succession has also brought problems to the surface. Many offshore vehicles were set up ten or fifteen years ago, at a point when families were smaller and asset bases simpler. As families expanded and assets diversified, those structures proved rigid. Updating them has often required extensive legal work across multiple jurisdictions.

How DIFC Foundations are being used

A DIFC Foundation is a standalone legal entity established under a UAE-based framework. It can own assets, sign contracts and continue indefinitely. Control is exercised by a council, with no shareholders in the traditional sense.

Families are now using foundations as central holding vehicles. A foundation may own a UAE operating company, a portfolio of investment properties and offshore subsidiaries at the same time. This reduces fragmentation and simplifies reporting.

The structure also allows families to define decision-making clearly. Council composition, reserved powers and succession mechanics are set out at inception. These are not theoretical features. They affect how banks interact with the structure, how investments are approved and how continuity is maintained if a founder steps back.

Asset protection through structure rather than distance

Families using DIFC Foundations are often looking for insulation of assets without losing oversight. Because assets are owned by the foundation rather than individuals, exposure to personal risk is reduced. At the same time, founders can retain influence through governance mechanisms rather than ownership.

This contrasts with older offshore arrangements where protection relied largely on jurisdictional distance. In the current environment, clarity and structure tend to be more effective than remoteness.

Succession planning in real terms

Succession is one of the areas where foundations are making a tangible difference. Families are increasingly addressing transition while founders are still actively involved.

With a DIFC Foundation, succession rules are written into the structure. Voting rights, benefit entitlements and decision-making thresholds can change over time according to predefined principles. This reduces reliance on discretionary decisions made under pressure.

In families where assets span operating businesses and passive investments, this clarity has become particularly important. It allows commercial continuity without forcing premature ownership transfers.

Governance that banks and partners recognise

Banks and commercial partners are paying closer attention to governance, especially when dealing with family-owned groups. DIFC Foundations provide a framework that counterparties understand.

Councils can include family members alongside independent professionals. Protector roles can be clearly defined. Records are maintained within a recognised legal system. This tends to reduce friction when opening accounts, refinancing assets or restructuring holdings.

For families with borrowing at group level, this credibility has practical consequences.

Residency and long-term planning

The rise in DIFC Foundations has coincided with a broader change in how families relate to the UAE. Since 2021, Dubai’s resident population has increased by more than 300,000 people, moving from just under 3.5 million to well over 3.8 million by 2024. A large share of that growth has come from professionals and business owners relocating with families.

These residents aren’t organising their affairs around short stays. School enrolments, property purchases and business formation all point to longer horizons. Legal structures are following that pattern.

Onshore foundations place the legal centre of gravity where families live and operate. For many, that alignment has simplified administration and reduced the need to explain offshore arrangements with limited local relevance.

Why foundations suit multi-asset families

As asset bases grow, complexity increases. Holding operating companies, real estate, liquid investments and private assets through separate vehicles often leads to duplication and risk.

Foundations are increasingly used to bring these elements together. A single governance framework can sit above diverse assets, with consistent reporting and oversight. Decisions are coordinated rather than siloed.

This has appealed particularly to families balancing commercial growth with long-term preservation, where different assets serve different purposes but need to sit within one coherent structure.

A change in how families structure wealth

The increased use of DIFC Foundations reflects how families are organising wealth in a region where they now live, invest and plan across generations. Offshore structures still exist, but they’re no longer the automatic starting point.

As regulatory clarity has improved and families have committed more deeply to the UAE, foundations have offered a practical alternative. They combine familiarity for international families with proximity to assets and decision-making.

For many families today, the question isn’t whether to move onshore, but how to design a structure that reflects how their lives and investments are actually organised.

Paulina Schulte
With an international background spanning Poland, Spain, Gibraltar, and the UAE, Paulina Schulte brings a truly global perspective to her work as Senior Client Advisor in complex international matters. Specialising in international business, she supports entrepreneurs, investors, and international families in navigating regulatory and legal landscapes across jurisdictions. Her focus is on efficient business structuring, strategic planning, and global residency and citizenship pathways, helping clients implement compliant, long-term solutions aligned with their commercial, personal, and mobility objectives.