This article is the primary mechanism for tax-neutral corporate restructuring. It allows assets and liabilities to be transferred between members of a 'Qualifying Group' without triggering a taxable gain or loss. This prevents tax friction during internal reorganisations. To qualify, entities must have at least 75% common ownership and meet other conditions, such as being UAE residents etc. The transfer is recorded at net book value. This relief is crucial for intra-group asset management, but it is clawed back if the asset or entity leaves the group within two years of the transfer.