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July 30, 2026
This article allows for the transfer of a Tax Loss from one Taxable Person to another, providing group relief. For a transfer to be permitted, several conditions must be met: both entities must be resident juridical persons, there must be at least 75% common ownership (directly, indirectly, or via a third person), and this ownership must be continuous. Furthermore, neither entity can be an Exempt Person or a Qualifying Free Zone Person, and they must share the same financial year and accounting standards. The transferred loss is subject to the recipient's 75% utilisation cap.
Chapter 11 - Tax Loss Provisions
Article 38 - Transfer of Tax Loss
[GTL Notes]
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