UAE - New Ministerial Decision on Tax Grouping

26 December 2024 – The Ministry of Finance of the United Arab Emirates (UAE) has introduced a new Ministerial Decision (MD) related to Corporate Tax (CT) Law provisions on tax grouping. This decision supersedes the previous MD 125 of 2023 and will be effective for tax periods starting on or after 1 January 2025.

Summary of updates

This updated decision provides clarity on several aspects relevant to tax groups under the CT Law. It encompasses:

Calculation of Taxable Income for a Tax Group: Guidelines for determining taxable income within a tax group.

Tax Loss Management: Procedures for managing tax losses for the tax group.

Intra-Group Transfers and Business Restructuring: Regulations covering internal transfers and restructuring transactions affecting tax groups.

Key changes

Enhanced Guidance: More clarity on instructions on the formation of tax groups under the CT Law.

Standalone Financial Statements: Increased emphasis on the need for standalone financial statements when a subsidiary exits a tax group.

A comprehensive alert with detailed analysis and implications will be issued soon. Stay tuned for further updates.

Contacts

We have a dedicated Business Tax team based in the UAE who have in-depth experience and can support you throughout your readiness journey. Please get in touch with one of our tax experts listed on the following page.

You can also contact us and submit all your queries on this email cituae@deloitte.com.