Private foundation (Liechtenstein, Panama, Malta, DIFC, ADGM)

A private foundation is a civil-law entity with its own legal personality that holds assets for beneficiaries or a purpose, run by a council under a charter and by-laws. It is the civil-law cousin of a trust and is popular for succession and asset protection. For UK tax the question is whether HMRC treats it as a company, a trust, or neither on the facts, and for a UK-resident founder who can benefit the Transfer of Assets Abroad and settlements rules usually remove any tax advantage.

• Families from civil-law countries who are uncomfortable with trusts.
• Non-UK-resident founders seeking succession planning, continuity of control and asset protection.

Reviewed 2026-09-29. Research, not advice.