This article provides for tax-neutral transfers of a business, or an independent part thereof, between Taxable Persons. Relief applies to mergers and reorganisations where the transfer is in exchange for shares or ownership interests and is undertaken in accordance with applicable State legislation. Key conditions include that all parties are UAE Taxable Persons (not Exempt or QFZP), share the same financial year and accounting standards, and the transaction is for valid commercial reasons. Any tax gain or loss is disregarded, with assets transferred at net book value. Relief is clawed back if the shares or business are disposed of within two years.