The European Soul, the Emirati Shield: Why the Money Is Split Between Milan and Dubai

In modern private wealth structuring, the foundation has re-emerged as a cornerstone vehicle, combining legal personality, asset segregation, and intergenerational control. Yet, the jurisdiction of incorporation determines whether the foundation functions primarily as a legacy institution or as an asset-protection entity.

A growing number of high-net-worth individuals now opt for a dual-foundation structure: one in Milan, to enshrine reputation, cultural presence, and continuity; and another in Dubai, to preserve, protect, and manage wealth efficiently across borders. The result is an elegant equilibrium between European permanence and Emirati flexibility.

1. The Milan Foundation

Under Articles 14 to 42 of the Italian Civil Code, further reinforced by Presidential Decree 361/2000 and the Legislative Decree 117/2017 (Codice del Terzo Settore), an Italian foundation (fondazione) is a legal person constituted by public deed or testamentary disposition, endowed with autonomous assets and governed by a defined statutory purpose.

Unlike associations, the Italian foundation is not member-based but purpose-based, it exists to perpetuate an idea, a mission, or a legacy. Once registered with the Prefecture or the competent regional authority, it acquires full legal personality and can own property, participate in companies, or even control them, provided the activity aligns with its institutional purpose.

A well-known example of this model is the Fondazione Giorgio Armani, established by Giorgio Armani to preserve the stylistic, ethical, and entrepreneurial integrity of his brand. Through this foundation, the designer ensured that the company’s governance and creative direction would remain consistent with his values, even beyond his lifetime. The foundation thus performs a dual legal function: it protects and ensures control of the Armani corporate group and fulfils a philanthropic mandate within Italy’s cultural and social environment.

This Italian model demonstrates how a foundation can transcend charitable intent and become a legal instrument of continuity, consolidating ownership, stabilizing governance, and preserving reputation. In Milan, such a structure can hold shares of an Italian or European company, supervise licensing arrangements, and reinvest proceeds in cultural or philanthropic initiatives. Properly constituted, it enjoys partial tax exemptions, simplified reporting obligations, and legal recognition as a public-interest entity. The foundation thereby transforms private wealth into a perpetual legal subject, operating within the boundaries of Italian civil law and under the oversight of the Prefettura.

2. The UAE Foundation

The United Arab Emirates has modernized its wealth-management architecture through the DIFC Foundations Law №3 of 2018 and the ADGM Foundations Regulations 2017, positioning the foundation as a key instrument of asset protection, wealth segregation, and succession planning. The UAE foundation, unlike a common-law trust, possesses independent legal personality and does not have any shareholder(s), assets are irrevocably transferred to the foundation, which is administered by a council for the benefit of designated beneficiaries or purposes, could be qualified recipient(s) or default recipient(s).

This structure objective is to make sure that assets are insulated from personal claims, family disputes, and creditor exposure. It creates a distinct patrimony, ring-fenced from the founder’s estate and immune to most external enforcement actions, provided the transfer was not fraudulent or preferential. Under the DIFC Foundations Law, the foundation enjoys perpetual succession, limited liability, and the ability to hold global assets, including real estate, intellectual property, and shares (or parts in LLC’s) in both UAE and foreign entities.

In practical terms, the UAE foundation operates as the core holding vehicle for global assets. It can own operating companies, bank accounts, yachts, aircraft, and intellectual-property portfolios, while the founder keeps strategic influence through the foundation charter and bylaws. Since the UAE imposes no personal income tax (Federal Decree-Law №47 of 2022 on the Taxation of Corporations and Businesses expressly excludes natural persons outside business scope) and no inheritance or wealth tax, the structure benefits from a low-tax environment without sacrificing transparency or compliance.

For high-net-worth individuals, particularly those relocating to Italy under the Art. 24-bis flat-tax regime, the UAE foundation provides the offshore dimension necessary for asset protection and tax neutrality. Properly established, it satisfies the economic-substance regulations under Cabinet Resolution №57 of 2020 and can act as a legitimate international asset-holding layer recognized under both UAE and international law.

3. Milan for Legacy, Dubai for Protection

The intersection between the Milan foundation and the UAE foundation gives rise to what may be called the “Milan–Dubai Foundation Axis”, a cross-jurisdictional structure uniting European prestige with Emirati security. In this architecture, the Milan foundation embodies purpose and visibility, while the UAE foundation ensures protection and continuity.

The arrangement operates as follows: the Milan foundation, constituted under Italian law, acts as the governance and legacy anchor, it may hold the shares (or parts) or voting rights of the family’s European companies, manage brand-licensing income, and pursue philanthropic or cultural objectives. Meanwhile, the UAE foundation, formed under DIFC or ADGM law, holds the international portfolio including foreign real estate, investment vehicles, or intellectual-property rights licensed to the operating companies.

This dual-foundation model achieves three legal and fiscal outcomes (i) Continuity of Governance, through the Milan entity, preserving European identity and brand integrity, (ii) Asset Protection, through the UAE entity, ring-fencing global wealth from personal exposure, and (iii) Tax Efficiency, by allocating foreign-source income under Italy’s flat-tax legal regime while leveraging the UAE’s tax-neutral jurisdiction.

This approach aligns with the principles articulated in my earlier articles:

“A Contract Does What Accounting Can’t: How an Agreement Can Reduce Your Tax Burden”, where I demonstrated that properly structured licensing arrangements between a holding company and an operating entity can lawfully reallocate taxable income and reduce effective tax exposure. Link: https://medium.com/@marounabouharb/a-contract-does-what-accounting-cant-how-an-agreement-can-reduce-your-tax-burden-579eba1de9fe; and

“A Vehicle for Wealth, Succession and Asset Protection for UAE Residents and European Individuals”, which explored the foundational legal regime under UAE law for segregating assets and ensuring intergenerational succession. Link: https://medium.com/@marounabouharb/a-vehicle-for-wealth-succession-and-asset-protection-for-uae-residents-and-european-individuals-78d3f5e6409a.

By combining those two methodologies, contractual licensing for income allocation, and foundation structuring for asset segregation, the Milan–Dubai axis enables a complete private wealth ecosystem: the Milan foundation perpetuates name, mission, and cultural legacy within the EU legal order, while the Dubai foundation consolidates, shields, and administers wealth under a zero-tax, confidentiality-oriented jurisdiction.

This model is not merely about tax optimization; it is about juridical coherence and strategic permanence. Milan gives the structure a soul: heritage, culture, and European substance. Dubai gives it a fortress: security, neutrality, and fiscal efficiency.

Together, they produce what every legacy requires: a legal architecture that outlives its architect.