6 September 2026 · The Election
The Article 17 Tax-Transparent Election
The Article 17 election treats a qualifying family foundation as a tax-transparent Unincorporated Partnership, so its income is attributed to the beneficiaries rather than taxed at the foundation. To qualify, the foundation must exist mainly for family wealth management, succession or charity, its beneficiaries must be identifiable natural persons or charities, and it must not be a vehicle to shelter a taxable business. Certain wholly-owned underlying entities can also be transparent.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
Flow-through treatment
Income passes to the beneficiaries.
- Foundation treated as a partnership.
- Income attributed to beneficiaries.
- Individual investment income usually outside CT.
- Removes the 9% at foundation level.
The conditions
Purpose and beneficiaries matter.
- Mainly wealth, succession or charity.
- Identifiable natural-person or charity beneficiaries.
- Not sheltering a taxable business.
- Underlying wholly-owned entities can qualify.
Frequently Asked Questions
For deciding whether to elect.
What does the election achieve?
It treats the foundation as tax-transparent, so income flows to the beneficiaries instead of being taxed at the foundation.
Who must the beneficiaries be?
Identifiable natural persons or public-benefit/charitable entities.
Can it shelter a business?
No. The foundation should not be used to conduct a taxable commercial business.
Can Exiloz make the election?
Yes. We confirm eligibility and file the Article 17 election.
Elect tax-transparency
Exiloz confirms eligibility and files your Article 17 election.