Qualifying Group Relief under UAE Corporate Tax Law

A juridical person may be a member of a Qualifying Group only if it is a Taxable Person that is either a UAE Resident Person or a Non-Resident Person with a UAE Permanent Establishment.
A transfer includes any transaction that conveys legal and economic ownership of an asset or liability, such as sale, exchange, relinquishment, sale-and-leaseback (treated as a sale), exercise of options, or transfer by universal title.
Qualifying Group Relief does not apply where assets or liabilities are transferred as a result of liquidation, dissolution, or merger in which an entity ceases to exist.
The Transferor and Transferee are treated as members of the same Qualifying Group only if all conditions are met:

• both are juridical persons and Taxable Persons
• ≥75% direct or indirect ownership exists between them, or by a common parent
• neither is an Exempt Person nor a Qualifying Free Zone Person
• both have the same Financial Year end
• both apply the same Accounting Standard
These conditions ensure tax neutrality while preventing abuse of intra-group restructuring relief.

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