It may be, but the rules around it have changed a great deal. A structure set up in the 2000s was designed for a world before automatic exchange of information, beneficial ownership registers and substance rules. It is worth checking it against today's rules.
What has changed
- CRS. The first automatic exchanges took place in September 2017 between 49 jurisdictions, with a further wave in September 2018. The UAE began exchanging from September 2018.
- Beneficial ownership registers. Many countries now record the real people behind companies, and tax authorities can obtain those records.
- Substance rules. After EU screening in the late 2010s, many low-tax jurisdictions brought in rules requiring companies in activities such as holding, financing or headquarters work to show real management, people and premises locally.
- Treaty anti-abuse rules. Under the OECD's multilateral instrument, a treaty benefit can be refused if obtaining it was one of the main purposes of an arrangement. The instrument entered into force for the UAE on 1 September 2019.
Signs a structure needs review
- Nobody can explain why it exists today.
- Family members have moved countries since it was set up.
- It relies on a tax treaty, or on directors who sign but do not decide.
- It has no clear record of who owns, controls and benefits from it.
Moving countries is a common trigger. See What happens to my offshore company when I move countries?
An example
Kenji, a Japanese investor now living in Dubai, set up an island holding company in 2004. Its local directors simply sign what he sends them. A review shows the company may be treated as managed from Dubai, and that his bank already reports it under CRS. He takes the tax findings to his lawyers, who advise on whether to keep, simplify or wind up the structure.
Quick questions
Does an old structure need closing down?
Not necessarily. The question is whether it is taxed and reported correctly under the rules that apply today.
How often should a structure be reviewed?
Whenever a family member moves country or the law changes, and every few years in any case.
Sources: OECD: First automatic CRS exchanges between 49 jurisdictions; OECD: Prevention of tax treaty abuse, third peer review report (United Arab Emirates); States of Guernsey: Economic substance.
General information as at October 2026, not advice. The examples are fictional and simplified, and the rules have conditions and exceptions not covered here. Take advice on your own circumstances, in each country involved, before acting.