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May 15, 2026

[Applicable for tax periods commencing on or after 1 January 2025]

[Repeals Ministerial Decision No. 125 of 2023]

This is not an Official Translation:

Tax Group for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 301 of 2024

Issued 09 Dec 2024 – (Effective from day following publication in the Official Gazette)

[GTL Notes]

Minister of State for Financial Affairs:

  • 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. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,

  • Ministerial Decision No. 125 of 2023 on Tax Group for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,

Has decided:

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:

Parent Company

:

A Resident Person that can make an application to the Authority to form a Tax Group with one or more Subsidiaries in accordance with Clause 1 of Article 40 of the Corporate Tax Law.

Subsidiary

:

A Resident Person in which the share capital or Membership or Partnership Capital, as applicable, is held by a Parent Company, in accordance with Clause 1 of Article 40 of the Corporate Tax Law.

Membership or Partnership Capital

:

The capital paid to a juridical person where the paid capital is divided into membership or partnership interests by a Person in order to be a member or a partner and have the rights of membership or partnership in that juridical person.

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.

Article 2 - Ownership Requirements