The United Arab Emirates (UAE) is fast becoming the global hub for high-net-worth individuals (HNWIs) and family offices. According to Henley & Partners, the UAE is forecast to attract a net inflow of around 9,800 millionaires in 2025, bringing with them an estimated USD 63 billion in investable wealth. Globally, millionaire migration is set to reach a record high of 142,000 relocations in 2025, up from 134,000 in 2024.
This surge is transforming the UAE into a centre of wealth, business, and family governance, with the Dubai International Financial Centre (DIFC) emerging as the jurisdiction of choice for many international families and corporates.
Historically, many families and businesses used offshore jurisdictions such as the British Virgin Islands (BVI) or the Cayman Islands to hold assets. These entities were often administered by nominee directors to demonstrate that management and control were outside the UAE.
However, with the influx of HNWIs to Dubai, this approach is increasingly risky. Under UAE Corporate Tax Law, companies are considered tax resident in the UAE if their Place of Effective Management (POEM) is in the country. This means that if directors live in Dubai, board meetings are held there, or strategic decisions are taken locally, an offshore company could be deemed a UAE tax resident - regardless of where it was incorporated.
Examples of tax exposure
In short, if the people, decision-making, and assets are in Dubai, the company risks being pulled into the UAE tax net, even if incorporated offshore.
Redomiciling an offshore structure to the DIFC ensures legal and tax domicile are consistent with operational reality. Instead of relying on artificial structures or offshore nominee directors, families and corporates can benefit from the credibility and recognition of a regulated financial free zone with a robust common law framework.
Key reasons include:
For decades, families defaulted to offshore structures in neutral jurisdictions. While these remain relevant in some cases, the global trend of tightening tax residency rules, coupled with the UAE’s rise as a wealth hub, means that families and corporates should reconsider whether their existing structures are still fit for purpose.
Redomiciling to the DIFC is not simply about tax - it is about aligning governance, credibility, and strategy with where families and businesses actually live and operate.
At Alpadis, we work closely with trusted partners for tax and legal input. But as fiduciary specialists with a presence in the UAE, Singapore, Hong Kong, Switzerland, Malaysia, and Japan, we see first-hand the challenges international families face when outdated structures collide with modern regulatory realities.
The movement of nearly 10,000 millionaires to the UAE in 2025 is part of a much larger trend: the centre of gravity for global wealth is shifting. For international families and corporates, relying on offshore structures in BVI or Cayman while living and operating in Dubai exposes them to unintended tax consequences and operational friction.
Redomiciling to the DIFC offers a credible, tax-efficient, and practical solution, aligning legal structures with reality. For families building multi-generational wealth and businesses expanding globally, the message is clear: the UAE is no longer just a place to live - it is where wealth is now structured, managed, and preserved for the future.
