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May 15, 2026

CTP007

Corporate Tax Public Clarification

Financial Statements and Related Audit Requirements for a Tax Group


Issue

The Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments ("Corporate Tax Law") applies to Tax Periods commencing on or after 1 June 2023.

A Tax Group is two or more Taxable Persons treated as a single Taxable Person according to the conditions of Article 40 of the Corporate Tax Law, where an application to form a Tax Group has been made to, and approved by, the Authority.

Where such an application has been approved, the Tax Group, as a Taxable Person, is required to prepare aggregated Financial Statements for the purpose of determining its Taxable Income.

The aggregated Financial Statements for the purposes of determining the Taxable Income of the Tax Group for Corporate Tax purposes shall be prepared by aggregating the standalone Financial Statements of the members of the Tax Group and eliminating the transactions between them ("Aggregated Financial Statements").

The Aggregated Financial Statements of the Tax Group are prepared specifically for Corporate Tax purposes and may deviate from the consolidated Financial Statements prepared under the accounting standards applied by the Parent Company (i.e., International Financial Reporting Standards ("IFRS") or IFRS for small and medium enterprises ("IFRS for SMEs"), collectively referred to in this public clarification as "IFRS").

This public clarification explains how the Aggregated Financial Statements should be prepared and the associated audit requirements for such Aggregated Financial Statements.

Summary

Tax Groups are required to prepare Aggregated Financial Statements under Article 3 of Ministerial Decision No. 114 of 2023. This requirement applies to all Tax Periods commencing on or after 1 June 2023.

Aggregated Financial Statements shall be prepared by aggregating the annual standalone Financial Statements of the members of the Tax Group.

While standalone Financial Statements of members of a Tax Group must be prepared in accordance with IFRS, not all the principles relating to consolidation under IFRS can apply to Aggregated Financial Statements of a Tax Group. As a result, there are certain deviations from IFRS that are necessary to prepare the Aggregated Financial Statements.