The DIFC Foundations Law DIFC Law No. 3/2018 (the Foundations Law) has taken the best of the different Common and Civil Law legislations on foundations and blended it in one unique law.

Amongst the innovations in the Foundations Law are:

• The DIFC Courts have the power to set aside transactions for mistake, along the lines of the jurisprudence which developed in England following the decision in Hastings-Bass-v-IRC [1974] 2 All ER 193 (Hastings-Bass) prior to its limitation by the decisions of the Supreme Court in Pitt v Holt [2013] UKSC 26 and Futter v HM Revenue and Customs [2013] UKSC 26 (Foundations Law articles 50-52).

• The capacity to compulsorily settle intra-Foundation disputes by arbitration (Foundations Law articles 54-55).

• Re-domiciliation of foundations (Foundations Law, articles 57-61), available also in the ADGM (ADGM Foundations Regulations 2017 articles 32-36) but not in the QFC.

• Recognition of foreign foundations (Foundations Law, article 65).