FAQ – Article 26 Transfers within a qualifying group
Source: https://mof.gov.ae/corporate-tax-faq/
- Will there be any relief available for transfers between group companies?
Yes. Companies that are part of a ‘Qualifying Group’ can transfer assets and liabilities between themselves at their net book value. This means that the transfer can be carried out tax neutrally (i.e. not give rise to a gain or loss for CT purposes).
- What is a Qualifying Group?
A Qualifying Group exists where all of the following conditions are met:
- The members are juridical persons which are UAE residents or non-resident persons that have a permanent establishment in the UAE;
● Either owns 75% or more of the other, or a third party owns 75% or more of both entities;
● Neither member is an Exempt Person;
● Neither member is a Qualifying Free Zone Person; and
● Members prepare their financial statements using the same accounting standards, and have the same financial year.