Mining Family $60M: Tax Optimization via RAK ICC Foundation

Background

Kazakhstan family, two adult children with British citizenship. Assets: mining business, London and Dubai real estate, $60M in liquid assets. Existing structure: operating holding in Kazakhstan, personal ownership of UK assets, direct Swiss bank accounts.

The Challenge

Three different jurisdictions generated three tax regimes simultaneously. The London real estate created potential Inheritance Tax exposure on transfer to British children (up to 40% on value above £325K). The Kazakh operating holding complicated dividend repatriation. Swiss accounts fell under CRS with automatic exchange to Kazakhstan. The family needed a unified architecture combining all jurisdictions without double taxation and with a clear succession plan for the British-citizen children.

The Solution

1. RAK ICC Foundation as the top ownership layer — consolidates all family assets into a single UAE-jurisdiction structure
2. Two IBCs (International Business Companies) in RAKEZ: one holding the operating business, one holding liquid investments
3. ADGM Trust for the London property — avoids UK Inheritance Tax while retaining operational control
4. Banking restructured through UAE-resident banks with correct CRS classification
5. Foundation regulation with discretionary distributions to the children, protecting assets from potential next-generation divorce

Structures Used

• RAK ICC Foundation
• RAKEZ IBC (×2)
• ADGM Trust
• UAE Tax Residency Certificate

Outcomes