UAE FTA Tax Group Reference 2026 — When and How UAE Companies Can Form Tax Groups
UAE Corporate Tax allows related UAE companies to form a Tax Group and file a combined UAE CT return. Here is the complete 2026 reference guide.
In this guide:
What Is a UAE CT Tax Group?
- Tax Group: Two or more UAE resident companies that meet the control conditions can elect to be treated as a single taxable person for UAE CT
- Benefit: Group companies can offset profits of one against losses of another within the group
Tax Group Eligibility Conditions
- UAE resident: All group members must be UAE resident entities (mainland or free zone)
- Control: Parent must own directly or indirectly at least 95% of shares and voting rights of each subsidiary
- Same financial year: All group members must have the same financial year
- Same accounting standards: All members must use same accounting standards
Tax Group Benefits
- Loss offset: Group member losses can be offset against another member’s profits
- Administrative efficiency: Single CT return for the group; one payment
- Intragroup transactions: Transactions between group members can be ignored for CT (no arm length rule within group)
Free Zone Companies in a Tax Group
- Mixed group: A Tax Group can include both free zone and mainland companies
- QFZP impact: If a free zone QFZP joins a Tax Group, it loses its individual QFZP status; group rate applies
- Planning: Including a QFZP in a Tax Group may not always be beneficial; model the tax impact carefully