Boru Consulting

The property SPV trap: a 9% UAE corporate tax the owner would not pay

Holding a Dubai property through an ADGM or DIFC SPV was the standard way to avoid the 4% transfer fee. Since UAE corporate tax arrived, that wrapper is a taxable person at 9% on net profit.

The same property held in personal name is outside corporate tax.

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The temporary non-residence trap

A UK founder who moves to Dubai, sells a business or crypto while non-resident, then returns within five years can find the gain pulled back into UK capital gains tax on return.

The temporary non-residence rules are mechanical, and split-year treatment does not switch them off.

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Boru Consulting across the UK, UAE and Ireland.

With offices across three key jurisdictions, we support founders, businesses, and private clients with their accounting, tax, governance, corporate, and cross-border requirements.

Our international presence allows our teams to work closely across jurisdictions, bringing together local expertise with a broader understanding of how businesses and structures operate internationally.

Whether you are establishing a presence in a new market, managing an existing international structure, or looking for ongoing advisory support, our team is here to help.

You build the vision.
We handle the noise.

The UAE Golden Visa and tax residency

A UAE Golden Visa gives you the right to live in Dubai. It does not, on its own, make you a UAE tax resident.

Tax residency is a separate test run by the Federal Tax Authority. A treaty certificate needs 183 days in the country, not just a visa in your passport.

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Moving to Dubai after the non-dom abolition: the UK inheritance tax tail

The UK non-dom regime ended on 6 April 2025. But moving to Dubai does not switch off UK inheritance tax.

Once you have been UK resident for 10 of the last 20 years, your worldwide estate stays in the 40% IHT net for a three-to-ten-year tail after you leave.

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Moving to Dubai from the UK: how many days until you stop paying UK tax?

There is no single magic number of days. UK tax residence is decided by the Statutory Residence Test, and it can keep you UK tax resident at well under 183 days.

With UK ties, someone leaving can be tax resident on far fewer days: one tie at 121 days, two ties at 91 days, three ties at 46 days.

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Selling a business or crypto after moving to Dubai

Moving to Dubai does not make the sale tax-free. What makes the gain free of UK tax is the sequence: becoming non-resident before the disposal, staying non-resident for more than five years, and not selling through a UAE company the UK still controls.

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A Dubai company does not automatically escape UK tax

A UAE company can be incorporated in days, with full foreign ownership. That does not mean HMRC stops taxing its profits.

Registering in Dubai changes the address. It does not, by itself, change where the company is taxed.

Three UK rules decide where the profits end up: corporate residence, Transfer of Assets Abroad, and Controlled Foreign Company rules.

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The DIFC and ADGM foundation

A DIFC or ADGM foundation is an orphan legal person, neither a company nor a trust. It is the structure families reach for once the offshore trust became settlor-transparent in 2025.

For a UK-resident founder it does not escape the settlements code or inheritance tax by itself.

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UAE Corporate Tax 2026: when a free zone company pays 0%

Yes, a UAE free zone company can pay 0% corporate tax in 2026. But the 0% rate is not automatic — it belongs to a Qualifying Free Zone Person that meets five conditions every year.

One wrong transaction can move the whole company to 9% for five years.

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