UAE CT allows multiple UAE entities to form a Corporate Tax Group for joint tax filing. Here is the complete 2026 guide.
In this guide:
What Is a UAE Corporate Tax Group?
- Definition: Two or more UAE taxable persons forming a single tax group; treated as one taxable person for UAE CT
- Benefit: Group losses offset group profits; simplified compliance; no inter-company transfer pricing
CT Group Conditions
- Parent ownership: Parent must own at least 95% of subsidiary
- UAE entities only: All members must be UAE-resident entities
- No exempt entities: Free zone persons (QFZPs) CANNOT be in same CT group as mainland companies (unless both elected standard CT)
- Same financial year: All group members must have same financial year
CT Group Benefits
- Loss offset: Entity A loss reduces Entity B profit in same tax period
- Transfer pricing: No transfer pricing required for intra-group transactions (within group)
- One return: Single consolidated CT return for the group
CT Group Application
- Apply: Submit CT group application on EmaraTax before start of group tax period
- Representative member: Designate one entity as the representative member for filing
Free Zone Complication
- QFZPs: Free zone companies qualifying for 0% rate are taxed differently; cannot generally join mainland CT group
- Free zone only group: Multiple QFZP entities can form a group with each other
- Elected standard CT: QFZP can join mainland group if it elects to pay standard CT rate (forfeits 0% rate)