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UAE: Guidance on Corporate Tax Groups Released

The Federal Tax Authority of the United Arab Emirates has issued a new guide elucidating the regulations surrounding the establishment of tax groups within the corporate income tax framework.


This guidance delineates the 'tax group' concept, outlines the eligibility criteria for forming or becoming a member of a tax group, specifies the conditions for the creation and dissolution of a tax group, elucidates the methodology for determining the taxable income of a tax group, and provides an overview of associated compliance obligations.


Upon establishment, a tax group treats the included taxpayers as a unified taxable entity. The consolidated taxable income of the group is computed, requiring only a single tax return for the entire group.


Resident juridical persons can form tax groups by submitting applications to the FTA, subject to meeting the stipulated conditions.


It's worth noting that the guide does not explicitly address the notion of a qualifying group as per Article 26 of the Corporate Tax Law. This article pertains to the tax-neutral transfer of assets and liabilities within a Qualifying Group for corporate tax purposes.


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