Common-law jurisdictions, for the structures that need one

Both are financial free zones with their own common-law systems and English-language courts - DIFC in Dubai, ADGM in Abu Dhabi. ADGM applies English common law directly, while DIFC has enacted its own body of law modelled on it. In practice the choice usually comes down to the specific vehicle you need, the registrar's requirements for it, and where the rest of your business sits.

A special purpose vehicle holds one thing - a property, a shareholding, an aircraft, a financing arrangement - and does nothing else. Keeping each asset in its own vehicle contains risk and makes it far simpler to sell, pledge or transfer that asset later without disturbing anything around it.

A foundation is a legal person that owns assets in its own name and is run by a council under a charter. A trust is a relationship in which trustees hold assets for beneficiaries. Foundations are often preferred by families from civil-law countries, where the trust concept is unfamiliar, because the structure looks and behaves like a company.

Vehicles such as ADGM SPVs and DIFC prescribed companies must maintain a registered agent and a registered address rather than taking their own premises. We act in that role, receive what the registrar sends, and keep the entity's filings current.

These entities operate within their own jurisdiction and internationally. Selling into the mainland market generally requires a separate mainland presence, a branch or a distributor - which is why these structures suit holding, investment and professional activity rather than local trading.

No. The threshold that matters is complexity rather than size: several assets in different countries, more than one generation involved, or an operating business alongside private investments. Where those apply, formal governance usually saves more than it costs.