Differently in each case. A trust, a foundation and a company each separate ownership, control and benefit in a different way, so tax authorities and CRS look at each differently. How each is taxed depends mainly on where the founder and each family member live for tax.
Who owns, who controls, who benefits
- Company. Shareholders own it, directors run it, and shareholders benefit through dividends or a rising share value.
- Trust. Trustees hold the assets for the beneficiaries. The person who set it up, the settlor, usually steps back. A protector may watch over the trustees.
- Foundation. The foundation owns its assets itself. A council manages it, and beneficiaries receive what its rules allow.
How tax authorities tend to look at them
Many countries tax a company on its own profits and tax shareholders when they receive dividends. Trusts and foundations get far more varied treatment. Some countries look through them and tax the founder or the beneficiaries directly. Others tax only what is paid out. A structure that works well for a family in one country can create a tax charge in another.
CRS reporting differs
Under the Common Reporting Standard, a company is usually reported through the people who own or control it, often using a 25% ownership marker. A trust is different. The settlor, trustees, any protector and the beneficiaries are all treated as controlling persons, whatever their percentage. Foundations are treated in an equivalent way, based on roles that resemble those of a trust. See What is reported about a trust or foundation under CRS?
An example
Rania, a Jordanian business owner living in Dubai, holds an investment portfolio. Her two sons live in Germany and Australia. Before choosing a structure, she asks an international tax specialist to look at how each option would be taxed and reported in all three countries. The comparison shows that one option would be taxed in a son's country on income he never received. She takes that tax comparison to her lawyers, who advise on the legal side.
Quick questions
Is a foundation the same as a trust for tax?
Not in every country. Some treat a foundation like a company, others like a trust, so the answer depends on where the family lives.
Does a company avoid CRS reporting?
No. Banks report the company and, for many companies, the people who own or control it to their countries of residence.
Sources: UAE Ministry of Finance: Guidance Notes for the Common Reporting Standard; UAE Ministry of Finance: CRS frequently asked questions.
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.