When does a family office need a head of tax? Eight signs it’s time

A family office needs a head of tax when its tax affairs span several countries or advisers and nobody is responsible for the overall position. The usual triggers are a relocation, a liquidity event, a new holding or foundation structure, or the arrival of corporate tax obligations in the UAE. At that point any single return is rarely the main risk, and the larger risk is a decision made in one country that creates a problem in another.

Not every family office needs a full-time hire. Many need senior judgement for a few days a month, which is where a fractional head of tax fits. The signs below apply either way.

1. Do you have advisers in three or more countries?

Each adviser answers for their own country. A UK adviser on a trust, a UAE adviser on corporate tax and a European adviser on property can each be right on their own terms and still produce advice that doesn’t fit together. Once there are three or more jurisdictions, someone needs to sit in the middle and check that the pieces connect. Families often discover the gap only when a tax authority asks a question that crosses borders.

2. Has a family member moved, or is a move planned?

Relocation is one of the commonest triggers. Moving to the UAE changes where a person is resident, but the old country rarely lets go immediately. The UK is a good example. From 6 April 2025 it ended the remittance basis for non-domiciled individuals and moved to a residence-based regime (Finance Act 2025, s. 40). UK inheritance tax now reaches the worldwide assets of anyone who has been UK resident for at least 10 of the previous 20 tax years. After they leave, that exposure continues for between 3 and 10 years, depending on how long they lived there (Finance Act 2025, s. 44, inserting s. 6A of the Inheritance Tax Act 1984). The timing, the order of steps and the evidence kept all count. Our guide to UAE tax residency for relocating families covers the UAE side.

3. Are you selling a business or receiving a large distribution?

A sale, partial exit or large dividend creates a tax question that is far cheaper to answer before signing than after. The questions include where the gain is taxed, whether a participation exemption applies, how proceeds are held afterwards and what the family’s residence position will be on the day the money arrives. A head of tax who sees the deal early can bring in the specialists it needs before anything is signed.

4. Do you hold assets through UAE companies, foundations or free zone entities?

UAE corporate tax applies to tax periods (usually the financial year) starting on or after 1 June 2023. Holding companies, special purpose vehicles and family offices set up as companies are generally taxable persons that must register and file, even where their income is exempt or taxed at 0%. Free zone entities need to meet conditions to keep the 0% rate, and foundations can apply to be treated as tax transparent under Article 17. The FTA’s public clarification CTP008, issued in September 2025, walks through how these entities are treated in typical family structures (FTA). If nobody in the family office can explain the status of each entity, that is a sign the family office needs a head of tax. See our guides to UAE corporate tax for family offices and family foundations under Article 17.

5. Does the family office charge, or pay, related parties?

A single family office that provides services to the family, its companies and its foundation is dealing with related parties. Under UAE corporate tax, transactions with related parties must meet the arm’s length standard, and payments to connected persons, such as owners and directors, are deductible only to the extent they reflect market value. CTP008 confirms that a family office that is a taxable person must be remunerated at arm’s length for services to related parties. Without someone owning this, fee arrangements tend to be set once and never revisited.

6. Is your annual tax advisory spend growing without a plan?

Many families pay several firms for tax advice. If nobody senior decides which questions to ask, which firm should answer them and whether the answers are acted on, the spend grows and the overall position doesn’t improve. A head of tax should be able to reduce duplication and put the budget into the decisions with the largest tax consequences.

7. Have you received a question from a tax authority you couldn’t answer quickly?

An enquiry is a test of the family’s records: if answering a routine question means chasing several advisers for documents and explanations, the underlying position probably isn’t documented.

8. Is the next generation taking on responsibility?

Succession brings tax questions in every country where beneficiaries live. When younger family members are resident in different countries from their parents, gifts, distributions and changes to structures can be taxed differently for each of them. A head of tax helps the family decide in advance and record the reasons.

What should you do if several of these apply?

Start by mapping the position. A useful first exercise lists every entity, every country, every adviser and every decision coming up in the next 12 to 18 months, with the tax questions attached to each. That map usually shows where the risks sit and who should own them.

Then decide on the model: if the work fills a senior person’s week, hire. If it doesn’t, a fractional head of tax on a retainer gives you the same senior ownership for a share of the time, and a team behind that person for the countries and taxes they don’t cover themselves. We compare the two in fractional vs full-time head of tax.

Within, by PBF, is fractional tax advisory: your tax team, within your business. We start with a private conversation about your international affairs, existing advisers and upcoming decisions, and if the service fits, we agree a written mandate and the first 90 days of work, beginning with that map. See how Within works.