This guide provides general guidance on Business Restructuring Relief under Article 27 of the UAE Corporate Tax Law, clarifying Ministerial Decision No. 133 of 2023. It details the tax-neutral treatment for transactions like mergers and demergers. Eligibility requires parties to be Taxable Persons and the restructuring to be for valid commercial reasons. Upon election, assets and liabilities are transferred at their net book value, with no immediate gain or loss recognized. Unutilized Tax Losses can also be transferred to the Transferee. The relief is subject to clawback provisions if the transferred business or ownership interests change within two years.