Trust
International property structures
A family that owns homes or investment property in more than one country pays tax and passes those properties on under each country's own rules. How each property is held, personally, through a company, a foundation or a trust, changes the tax on buying it, holding it, selling it and leaving it, and it changes which court decides who inherits. The right structure is rarely the same for a London house and a Dubai apartment. [1][2][3][4][5]
Your situation
- A London home kept after moving to Dubai, and no plan for the UK tax it still attracts.
- Dubai property bought personally, so it passes under UAE inheritance law on death and the bank accounts tied to it freeze until a court order.
- Investment property in several countries, each with its own tax return, held in a mixture of names.
- A wish to pass property to children without a sale, and without a dispute between heirs in two countries.
What the structure decides
The United Kingdom (official rules, last checked 29 October 2026)
- Selling. A non-UK resident pays UK capital gains tax on UK land and property, including shares in a company that gets 75% or more of its value from UK land where the seller holds 25% or more. Residential sales must be reported and paid within 60 days of completion, even when no tax is due. [1]
- Inheritance. Since 6 April 2017, UK residential property held through a foreign close company or partnership is within UK inheritance tax to the extent of the shares' value that comes from that property. Related loans are caught too. [2]
- Buying through a company. A company buying a UK home for more than £500,000 pays stamp duty land tax at 17%, with reliefs for rental businesses and some other uses. A 2% surcharge applies to non-UK resident buyers in England and Northern Ireland. [3]
- Holding through a company. The annual tax on enveloped dwellings applies to company-held UK homes worth more than £500,000: for 1 April 2026 to 31 March 2027, from £4,600 (over £500,000) to £303,450 (over £20 million) a year, with reliefs including for property rental businesses. [4]
Dubai
- Who can be the registered owner. DIFC entities, including foundations, can hold Dubai property outside the DIFC in areas open to foreign owners under a 2018 agreement with the Dubai Land Department. ADGM foundations and other ADGM entities can under a similar agreement, in freehold areas. RAK ICC companies with individual shareholders can register freehold property under a 2019 agreement, with a no-objection letter. No official source confirms the same for RAK ICC foundations. [5]
- Succession. Property held personally passes under UAE law on death. Property held by a foundation or company passes under the foundation's charter or the company's shares, so the succession plan sits at that level. [6]
- Tax. The UAE has no personal income tax or inheritance tax. A company that holds property must register for UAE corporate tax; how its income is taxed depends on where it is registered and the kind of income. [7]
Other countries. Each has its own rules on foreign owners, company ownership, annual property taxes and inheritance. A tax adviser and a lawyer in that country confirm them before anything is bought or moved.
What we do
- We list every property by country, owner, value, loans and use, and the outcome you want for each.
- We set out how personal, company, foundation and trust ownership compare for each property, with the UK and UAE rules above and the rules of any other country in view.
- We design the holding structure and the order in which properties move into it, so a transfer does not trigger a tax that could have been avoided by timing.
- We form and administer the UAE companies in the structure, including RAK ICC companies, keep their accounts and advise on their UAE tax.
- We coordinate the tax advisers, lawyers, registered agents and banks in each country to one timetable.
What a licensed partner does
- A UK tax adviser advises on UK capital gains, inheritance, stamp duty and the annual tax on enveloped dwellings, and files UK returns.
- A tax adviser or lawyer in each other country does the same for its rules.
- A law firm drafts transfers, charters and deeds.
- A licensed registered agent files a DIFC or ADGM foundation. You engage it directly.
- The Dubai Land Department decides each registration.
- A licensed bank provides any mortgage. You choose and contract with it directly.
You appoint and contract with each one directly. Under a Full Mandate, we run the whole plan.
Related guides
- UK inheritance tax for non-residents →
- Is there a UK exit tax? →
- Holding companies in the UAE →
- Trusts and foundations in the UAE →
Questions people ask
Should I hold my UK property through a company after moving to Dubai?
It depends on the property's value, whether it is let, and your plans for it. Since 2017 a company does not keep a UK home out of UK inheritance tax, and a company-held home over £500,000 pays an annual charge. A UK tax adviser runs the numbers for your case. [2][4]
Can a foundation own property in Dubai?
A DIFC or ADGM foundation can, in areas open to foreign ownership. No official source confirms the same for a RAK ICC foundation. [5]
Do I pay UK tax when I sell my UK home from Dubai?
UK capital gains tax applies to non-residents selling UK property, and the sale must be reported within 60 days of completion. Reliefs may reduce the gain; a UK tax adviser confirms which apply. [1]
This page is general information, not tax or legal advice. Rules and figures change; they were last checked on 29 October 2026.
Marlborough Gulf does not give investment, pension or insurance advice. Regulated services are provided by licensed firms, who contract with you directly.
Sources
- HMRC, Tax when you sell property, land or shares in the UK if you're not a UK resident, GOV.UK, updated 13 Jan 2026. https://www.gov.uk/guidance/capital-gains-tax-for-non-residents-uk-residential-property
- HMRC Inheritance Tax Manual, IHTM04311 Finance (No 2) Act 2017 changes: UK residential property, updated 7 Apr 2026. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04311
- HMRC, Stamp Duty Land Tax: corporate bodies, GOV.UK, updated 2 May
https://www.gov.uk/guidance/stamp-duty-land-tax-corporate-bodies
- HMRC, Annual Tax on Enveloped Dwellings: the basics, GOV.UK, updated 4 Mar 2026. https://www.gov.uk/guidance/annual-tax-on-enveloped-dwellings-the-basics
- Gulf News, "DLD opens investment lane for DIFC entities", 1 Nov 2018; Stephenson Harwood, "The Ownership Of Real Estate In Dubai By ADGM Registered Entities", 15 Sep 2020 (on Legal 500); Gulf Today, "DLD strengthens ties with RAK government entities", 16 Jul 2019. https://gulfnews.com/business/property/dld-opens-investment-lane-for-difc-entities-1.2107712 https://www.legal500.com/intelligence/united-arab-emirates/real-estate-and-construction/the-ownership-of-real-estate-in-dubai-by-adgm-registered-entities https://gulftoday.ae/Business/2019/07/16/DLD-strengthens-ties-with--RAK-government-entities
- Federal Decree-Law No. 25 of 2025, Civil Transactions Law, Article 17(5); in force 1 Jun 2026. Dubai Law No. 15 of 2017, Article 4(b)(1). https://uaelegislation.gov.ae/en/legislations/4011 https://dlp.dubai.gov.ae/Legislation%20Reference/2017/Law%20No.%20%2815%29%20of%202017.html
- PwC Worldwide Tax Summaries, UAE: individual, other taxes, reviewed 9 Sep 2026; Federal Decree-Law No. 47 of 2022 (Corporate Tax Law). https://taxsummaries.pwc.com/united-arab-emirates/individual/other-taxes https://mof.gov.ae/wp-content/uploads/2022/12/Federal-Decree-Law-No.-47-of-2022-EN.pdf