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May 15, 2026

Under Article 54 of the Corporate Tax Law, this decision requires Tax Groups to prepare and maintain audited special purpose Aggregated Financial Statements. These statements are created by aggregating the standalone financials of the parent and each subsidiary member. The framework, detailed in Article 3, mandates the elimination of transactions between members and general adherence to IFRS, with specific exceptions for business combinations. The accounting policies must be uniform across all members. The final audited statements must be submitted to the FTA within nine months from the end of the tax period.

This is not an Official Translation:

Determination of the Requirements for Preparing and Maintaining Audited Special Purpose Financial Statements for a Tax Group for the purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses and its amendments

Federal Tax Authority Decision No. 7 of 2025

Issued 16 July 2025 - (Effective for tax periods commencing on or after 1 January 2025)

The Chairman of the Board of Directors of the Federal Tax Authority has decided:

Having reviewed the Constitution,
Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority, and its amendments,
Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,
Cabinet Decision No. 74 of 2023 on the Executive Regulation of Federal Decree-Law No. 28 of 2022 on Tax Procedures,
Ministerial Decision No. 114 of 2023 on the Accounting Standards and Methods for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Ministerial Decision No. 301 of 2024 on Tax Group for the Purposes of Federal Decree- Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Ministerial Decision No. 84 of 2025 on Audited Financial Statements for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Decision of the Chairman of the Board of Directors No. 9 of 2021 on the Delegation to the Vice Chairman of the Board of Directors of the Federal Tax Authority, and
Pursuant to the approval of the Board of Directors on the memorandum passed on 11/07/2025 on the Determination of the Requirements for Preparing and Maintaining Audited Special Purpose Financial Statements for a Tax Group.

Article 1 - Definitions

Words and expressions in this Decision shall have the same meanings specified in the Federal- Decree Law No. 47 of 2022 referred to above ("Corporate Tax Law"), with the exception of the following expression which shall have the meaning assigned against it, unless the context otherwise requires:

Aggregated Financial Statements

Financial Statements prepared on the basis of the aggregation of the standalone Financial Statements of the Parent Company and each Subsidiary that is a member of the Tax Group in accordance with the framework specified in Article 3 of this Decision.