Website Last updated:

July 30, 2026

This guide explains the rules for forming and operating a Tax Group under Article 40. It details the conditions for a Parent Company and its Subsidiaries to be treated as a single Taxable Person, including the 95% common ownership and control requirements. The guide clarifies that all members must be resident juridical persons and not Exempt or Qualifying Free Zone Persons. It outlines the benefits, such as filing a single consolidated tax return, and the key tax implications, including the elimination of intra-group transactions, simplifying compliance for consolidated corporate structures.

Tax Groups

Corporate Tax Guide | CTGTGR1

January 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. What is a Tax Group?

4. Conditions to form a Tax Group

Example 1: Resident Subsidiaries of a foreign parent forming a Tax Group

Contents