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May 15, 2026

This Decision outlines transitional rules for adjusting Taxable Income for certain assets owned before a Taxable Person's first tax period, providing relief under Article 61 of the Corporate Tax Law. It details the elective relief for gains on immovable property, intangible assets, and financial assets/liabilities measured on a historical cost basis. Taxpayers can choose one of two adjustment options for immovable property (market value or time apportionment) and must use the time apportionment method for intangible assets. These elections are generally irrevocable and must be made in the first Tax Return.

This is not an Official Translation:

Adjustments Under the Transitional Rules for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 120 of 2023

Issued 16 May 2023 – (Effective the day after publishing in the Official Gazette)

[GTL Notes]

The Minister of State for Financial Affairs has decided:

Having reviewed the Constitution,
Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
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,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,

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'), and the following words and expressions shall have the meanings assigned against each, unless the context otherwise requires:

Accounting Standards	:	The accounting standards specified in a decision issued by the Minister for the purposes of the Corporate Tax Law.
Financial Statements	:	A complete set of statements as specified under the Accounting Standards applied by the Taxable Person, which includes, but is not limited to, statement of income, statement of other comprehensive income, balance sheet, statement of changes in equity and cash flow statement.
Immovable Property	:	Immovable property as defined in a decision issued by the Cabinet for the purposes of the Corporate Tax Law.
Qualifying Immovable Property	:	Immovable Property that meets the conditions under Clause (1) of Article 2 of this Decision.
Intangible Asset	:	An intangible asset as defined in the Accounting Standards applied by the Taxable Person.
Qualifying Intangible Asset	:	Intangible Asset that meets the conditions under Clause (1) of Article 3 of this Decision.
Financial Asset	:	Financial asset as defined in the Accounting Standards applied by the Taxable Person.
Financial Liability	:	Financial liability as defined in the Accounting Standards applied by the Taxable Person.
Qualifying Financial Asset	:	Financial Asset that meets the conditions under Clause (1) of Article 4 of this Decision.
Qualifying Financial Liability	:	Financial Liability that meets the conditions under Clause (1) of Article 4 of this Decision.