The UAE Corporate Tax Law allows multi-entity businesses to apply for a tax group under a single Tax Registration Number (TRN), streamlining compliance and reducing administrative costs by requiring only one corporate tax return instead of multiple filings. The Federal Tax Authority (FTA), through Decision No. 3 of 2024, has established eligibility criteria, application procedures, and compliance requirements for tax groups under UAE corporate tax.
Also read: Corporate Tax Filing in UAE
This guideline details the corporate tax registration process, key benefits, associated fees, and deadlines for tax groups in the UAE.
What is a Tax Group Under UAE Corporate Tax?
A tax group comes into existence when two or more resident companies opt to be taxed as an entity for corporate tax in the UAE. This implies:
- Only one return has to be filed and not multiple returns, one for each company.
- Intra-group transactions do not come within the purview of tax liability, thereby minimizing compliance issues.
- Profits and losses can be set off against one another in the group.
To constitute a tax group in the UAE, businesses must meet the eligibility criteria outlined by the FTA.
Eligibility Criteria of Corporate Tax Registration as a Tax Group
The following are the conditions to be satisfied by the companies to get registered as a tax group for corporate tax purposes in the UAE:
- All entities should be resident juridical persons in the UAE.
- The parent owns at least 95% of each subsidiary’s shares, voting rights, and entitlement to profits.
- All members shall have the same financial year and accounting method.
- No member shall be an Exempt or Qualifying Free Zone person.
- The tax group application shall be made jointly via the FTA portal.
If these aforementioned requirements are not met, FTA will reject the application for a tax group.
Guide to Corporate Tax Registration for Tax Groups in UAE
Step 1: Gather Required Documents
Documents required for the application as a tax group include but are not limited to:
- Trade License of all the respective members
- MOA and Shareholding Structure
- Ownership proof of the parent company showing a minimum 95% control
- Copies of financial statements of all member entities; Emirates ID & Passport, Visa copies of the owners and partners; Tax Registration Numbers (TRNs) under Individual Entities if independently registered before this tax group application head.
Step 2: Application through FTA Portal
- Login to the FTA e-Services Portal.
- Click “Corporate Tax Registration” and select “Tax Group Registration”
- Put in the details of the parent company-TRN, legal form, and ownership structure
- Add the subsidiary companies, attach the required documents
- Apply; wait for the approval from the FTA
Step 3: Obtain the Corporate Tax Registration Number (TRN) of the Tax Group
The application is approved, one TRN is to be obtained by the tax group, from where all of the group members would be charged for tax collectively
Also read: Deregistration or Amendment in a Tax Group
Subsidiaries’ Corporate Tax Registration Deadline Before Forming a Tax Group
All the subsidiary companies have to be registered for corporate tax individually with the FTA before applying for tax group registration. The deadlines for corporate tax registration of subsidiaries are as follows, depending on the month in which the trade license was issued:
License Issuance Month | Registration Deadline |
January – February | 31 May 2024 |
March – April | 30 June 2024 |
May | 31 July 2024 |
June | 31 August 2024 |
July | 30 September 2024 |
August – September | 31 October 2024 |
October – November | 30 November 2024 |
December | 31 December 2024 |
Subsidiaries that were incorporated from 1 March 2024 and onward are to be registered within three months from the date of incorporation. Upon registering all the subsidiaries, the parent company may now apply to tax group formation. Late registration may attract some penalties imposed by the FTA.
Penalties for Late or Non-Registration
Non-registering of a tax group within the deadline set by the FTA results in:
- AED 10,000 for non-registration
- Additional penalties due to late filing of tax
- Restriction on adjustment of losses and tax deductions
To avoid this fine, timely registration is key to ensure.
Also read: Guide to Group Relief Under UAE Corporate TaxA
Benefits of Corporate Tax Registration as a Tax Group
- One corporate tax return by the tax group, instead of multiple returns by each entity constituting the group.
- No Tax on Intra-Group Transactions: No tax is payable by a company for intra-group transactions.
- Tax Loss Offset: It allows the application of losses at the company level against the total taxable income. It reduces administrative work by combining the tax statements.
- This will help companies reduce their tax liability with FTA compliance considerably by getting registered as a tax group.