A UAE resident group of companies will be able to nominate to form a tax
group, capable of being treated as a single
taxable person if the parent company holds at least 95% of the share capital and voting rights of
its subsidiaries.
To form a tax group, neither the parent company nor any of the
subsidiaries can be an exempt person or a free zone
entity benefitting from the 0% CT rate, and all group members must use the same financial year. For
other groups of
companies which do not meet the 95% threshold, the CT regime will allow the transfer of losses
between group companies,
provided that they are at least 75% commonly owned.