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July 30, 2026

This guide explains the provisions for Qualifying Group Relief under Article 26, enabling tax-neutral transfers of assets and liabilities between members of a Qualifying Group. It details the conditions for forming a group, including the 75% common ownership requirement, and specifies that members must be Taxable Persons. The guide clarifies that upon election, transfers are treated at net book value, resulting in no taxable gain or loss. It also outlines the critical two-year clawback provisions that reverse the relief if the group structure changes post-transfer, preventing tax avoidance.

Qualifying Group Relief

Corporate Tax Guide | CTGQGR1

April 2024

1. Glossary

2. Introduction

2.1. Overview
2.2. Purpose of this guide
2.3. Who should read this guide?
2.4. How to use this guide
2.5. Legislative references
2.6. Status of this guide

3. Qualifying Group Relief: General aspects

Example 9: Calculation of net book value

In addition, after the clawback has been triggered, the Transferee will no longer make the adjustments required under Article 4 of the Ministerial Decision No. 134 of 2023 (as explained further in Section 5.3). However, if the transfer was recorded in the Financial Statements at a value that differs from the Market Value, the Transferee will be required to make adjustments under Article 3 of Ministerial Decision No. 134 of 2023.

Contents