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May 15, 2026

This Decision specifies adjustments to convert Accounting Income into Taxable Income per Article 20 of the Corporate Tax Law. Key adjustments include incorporating unrealised gains/losses from financial statements, replacing the equity method with the cost method of accounting, and detailing rules for Taxable Persons electing to use the realisation basis for gains and losses. It also mandates specific adjustments for transfers between Related Parties, within a Qualifying Group (Article 26), and under Business Restructuring Relief (Article 27) to ensure proper tax treatment is applied to these transactions.

This is not an Official Translation:

General Rules for Determining Taxable Income for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 134 of 2023

Issued 29 May 2023 - (Effective the day after publishing in the Official Gazette)

[GTL Notes]

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.
Accrual Basis of Accounting	:	An accounting method under which the Taxable Person recognises income when earned and expenditure when incurred.
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.
Equity Method of Accounting	:	The equity method of accounting as defined in the International Financial Reporting Standards ('IFRS'), or an equivalent method of accounting under the Accounting Standards applied by the Taxable Person.
Cost Method of Accounting	:	The cost method of accounting as defined in the International Financial Reporting Standards ('IFRS'), or an equivalent method of accounting under the Accounting Standards applied by the Taxable Person

Minister of State for Financial Affairs has decided:

Article 1 - Definitions

Article 2 - Other Adjustments to the Accounting Income for Determining the Taxable Income