UAE Corporate Tax Group Relief — Can Group Companies Offset Losses? 2026
UAE corporate tax allows related companies to form a tax group or transfer losses between group entities. Here is the 2026 guide on UAE CT group provisions.
In this guide:
UAE CT Tax Group
Two or more UAE resident companies can form a UAE CT Tax Group if:
- Parent company holds at least 95% in each subsidiary
- All group members have the same financial year end
- All group members are UAE resident persons (not QFZP unless all QFZPs elect together)
- No insolvency proceedings against any member
Benefits of UAE CT Tax Group
- Group members file a single UAE CT return (administrative efficiency)
- Losses of one group member can be offset against profits of another
- Intra-group transactions are eliminated for CT purposes (no gains on related party transfers within the group)
Tax Loss Transfer (Without Forming a Group)
Even without a formal tax group, UAE allows loss transfers between related parties under certain conditions:
- Transfer of tax losses from a company making losses to a related company making profits
- Both companies must be UAE resident
- Relationship threshold: 75% common ownership
- Application to FTA required for approval of loss transfer
Qualifying Free Zone Persons and Tax Groups
QFZPs cannot join a tax group that includes non-QFZP members (this would taint the QFZP status). A separate QFZP group can be formed but this is complex — take UAE CT specialist advice.