Corporate Tax
Tax-efficient restructuring using tax groups, qualifying group transfers, loss transfers and business restructuring relief.
Moving assets between companies, merging businesses or forming a holding structure can trigger Corporate Tax on gains that have not been realised in cash. UAE law offers reliefs that defer or remove that tax, as long as strict conditions are met. We help you plan restructurings so they work commercially and for tax.
No unexpected tax
Gains on internal transfers are deferred where the law allows.
Simpler compliance
A tax group files one return instead of one per company.
Use losses fully
Losses in one company can offset profits in another where conditions are met.
Avoid clawbacks
We flag the holding periods and events that could undo the relief.
In-depth guide
01Choosing the right relief
UAE Corporate Tax offers several tools for groups. A tax group consolidates members into one taxpayer. Qualifying group relief lets assets move between related companies at book value. Business restructuring relief covers mergers, demergers and transfers of a business for shares. Loss transfer relief allows losses to be used across the group.
Each has its own ownership thresholds, conditions and consequences, so the right choice depends on what you want the structure to achieve.
02Planning around the conditions
Common conditions include residency, matching financial years and accounting standards, and minimum ownership levels that must be maintained. Free Zone and exempt entities are often excluded.
Many reliefs also have a clawback period. Selling the asset or breaking the group within that window can bring the deferred gain back into tax, so we map future plans as part of the advice.
03Looking beyond Corporate Tax
Restructurings also have VAT, transfer pricing, licensing and sometimes real estate registration consequences. A transfer of a going concern may be outside the scope of VAT, but only if the conditions are documented.
We coordinate these points with your legal advisers so the restructuring is implemented in one consistent sequence.
- 1
Define goals
We understand the commercial reasons and the end structure you want.
- 2
Test reliefs
We check which reliefs apply and what conditions must be kept.
- 3
Step plan
We set out the order of steps, documents and filings.
- 4
Implement
We support applications, elections and the return disclosures.
Resident companies with 95% common ownership and control can apply to be treated as a single taxable person, filing one return and ignoring transactions between members.
Corporate Tax
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