# Tax Group

**URL:** https://uaectfaqs.com/c/tax-group/7.md

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## [About the Tax Group category](https://uaectfaqs.com/t/about-the-tax-group-category/12)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 7, 2024, 8:38am UTC](https://uaectfaqs.com/t/about-the-tax-group-category/12 "2024-09-07T08:38:38Z")

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About UAE Tax Groups A Tax Group allows multiple affiliated companies to be treated as a single taxable entity for Corporate Tax purposes in the UAE. By forming a Tax Group, businesses can consolidate their profits and …

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## [Does the 75% limit on Tax Loss utilization apply to individual members of the Tax Group?](https://uaectfaqs.com/t/does-the-75-limit-on-tax-loss-utilization-apply-to-individual-members-of-the-tax-group/135)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:23am UTC](https://uaectfaqs.com/t/does-the-75-limit-on-tax-loss-utilization-apply-to-individual-members-of-the-tax-group/135 "2024-09-23T10:23:13Z")

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The utilization of pre-Grouping Tax Losses is not limited to 75% of the Taxable Income attributable to relevant member of the Tax Group.

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## [What is the order of utilization when there are multiple unutilized Net Interest Expenditures?](https://uaectfaqs.com/t/what-is-the-order-of-utilization-when-there-are-multiple-unutilized-net-interest-expenditures/138)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:24am UTC](https://uaectfaqs.com/t/what-is-the-order-of-utilization-when-there-are-multiple-unutilized-net-interest-expenditures/138 "2024-09-23T10:24:55Z")

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If a Tax Group has unutilised Net Interest Expenditure and it also has members with pre-Grouping unutilized Net Interest Expenditure, the Net Interest Expenditure should be utilised in the order in which the amount was i…

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## [What is the application of General Interest Deduction Limitation Rule to Tax Group?](https://uaectfaqs.com/t/what-is-the-application-of-general-interest-deduction-limitation-rule-to-tax-group/137)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:24am UTC](https://uaectfaqs.com/t/what-is-the-application-of-general-interest-deduction-limitation-rule-to-tax-group/137 "2024-09-23T10:24:36Z")

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As the Tax Group is treated as a single Taxable Person thus General Interest Deduction Limitation Rule shall apply at the Tax Group level. Accordingly, the resulting disallowed Net Interest Expenditure carried forward ma…

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## [What is the order for utilization of Tax Losses by Tax Groups according to UAE Corporate Tax Law?](https://uaectfaqs.com/t/what-is-the-order-for-utilization-of-tax-losses-by-tax-groups-according-to-uae-corporate-tax-law/136)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:24am UTC](https://uaectfaqs.com/t/what-is-the-order-for-utilization-of-tax-losses-by-tax-groups-according-to-uae-corporate-tax-law/136 "2024-09-23T10:24:05Z")

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Pre-Grouping Tax Losses: These must be utilized before Tax Losses of the Tax Group. Pre-Grouping Tax Losses: If there are multiple pre-Grouping Tax Losses, the Parent Company determine the order in which they are utiliz…

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## [Are there any restrictions on utilizing carried forward Tax Losses?](https://uaectfaqs.com/t/are-there-any-restrictions-on-utilizing-carried-forward-tax-losses/134)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:20am UTC](https://uaectfaqs.com/t/are-there-any-restrictions-on-utilizing-carried-forward-tax-losses/134 "2024-09-23T10:20:04Z")

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Yes, the utilization of carried forward Tax Losses is limited to up to 75% of the Taxable Income at the Tax Group level. This restriction applies to the Tax Group as a whole, not to individual members.

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## [How are pre-Grouping Tax Losses utilized?](https://uaectfaqs.com/t/how-are-pre-grouping-tax-losses-utilized/133)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:18am UTC](https://uaectfaqs.com/t/how-are-pre-grouping-tax-losses-utilized/133 "2024-09-23T10:18:54Z")

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Pre-Grouping Tax Losses must be utilized against the Taxable Income of the Tax Group in the subsequent Tax Period before utilizing any carried forward Tax Losses of the Tax Group. This means that pre-Grouping Tax Losses …

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## [What happens to Tax Losses if a member leaves the Tax Group?](https://uaectfaqs.com/t/what-happens-to-tax-losses-if-a-member-leaves-the-tax-group/132)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:18am UTC](https://uaectfaqs.com/t/what-happens-to-tax-losses-if-a-member-leaves-the-tax-group/132 "2024-09-23T10:18:34Z")

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If a Subsidiary leaves the Tax Group, any Tax Losses incurred while it was part of the group remain with the Tax Group. However, if the entire Tax Group ceases to exist, such Tax Losses will remain with the Parent Compan…

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## [What happens to existing Tax Losses when a new Subsidiary joins a Tax Group?](https://uaectfaqs.com/t/what-happens-to-existing-tax-losses-when-a-new-subsidiary-joins-a-tax-group/131)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:17am UTC](https://uaectfaqs.com/t/what-happens-to-existing-tax-losses-when-a-new-subsidiary-joins-a-tax-group/131 "2024-09-23T10:17:50Z")

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If a Subsidiary joins a Tax Group, its existing unutilised Tax Losses become pre-Grouping Tax Losses that can only be offset against the Taxable Income of the Tax Group insofar as this income is attributable to the relev…

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## [What are Pre-Grouping Tax Losses, and how do they affect a Tax Group?](https://uaectfaqs.com/t/what-are-pre-grouping-tax-losses-and-how-do-they-affect-a-tax-group/130)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:17am UTC](https://uaectfaqs.com/t/what-are-pre-grouping-tax-losses-and-how-do-they-affect-a-tax-group/130 "2024-09-23T10:17:01Z")

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Pre-Grouping Tax Losses are the unutilized Tax Losses of a Subsidiary that joins a Tax Group. These losses must be utilized before the Tax Group’s own Tax Losses. If a Tax Group is formed, losses incurred before the Corp…

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## [Can a transferred Tax Loss be utilized immediately within the Tax Group?](https://uaectfaqs.com/t/can-a-transferred-tax-loss-be-utilized-immediately-within-the-tax-group/102)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 1\
**Last updated:** [September 10, 2024, 6:07am UTC](https://uaectfaqs.com/t/can-a-transferred-tax-loss-be-utilized-immediately-within-the-tax-group/102 "2024-09-10T06:07:07Z")

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Can a transferred Tax Loss be utilized immediately within the Tax Group?

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## [What are Tax Losses, and how can they be carried forward in a Tax Group?](https://uaectfaqs.com/t/what-are-tax-losses-and-how-can-they-be-carried-forward-in-a-tax-group/129)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:15am UTC](https://uaectfaqs.com/t/what-are-tax-losses-and-how-can-they-be-carried-forward-in-a-tax-group/129 "2024-09-23T10:15:36Z")

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Tax Losses refer to the negative balance of a Taxable Person’s income after deducting allowable expenses and deductions. In a Tax Group, Tax Losses from one period can be carried forward to subsequent periods, provided c…

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## [Under which situations attribution is required for taxable income within a Tax Group?](https://uaectfaqs.com/t/under-which-situations-attribution-is-required-for-taxable-income-within-a-tax-group/128)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:15am UTC](https://uaectfaqs.com/t/under-which-situations-attribution-is-required-for-taxable-income-within-a-tax-group/128 "2024-09-23T10:15:05Z")

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A Tax Group is required to calculate the Taxable Income attributable to one or more of its members in the following situations: - When a member of the tax group has unutilized pre-Grouping Tax Losses. When a member…

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## [How should be the treatment of the Subsidiaries which have shareholders outside the Tax Group?](https://uaectfaqs.com/t/how-should-be-the-treatment-of-the-subsidiaries-which-have-shareholders-outside-the-tax-group/127)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:13am UTC](https://uaectfaqs.com/t/how-should-be-the-treatment-of-the-subsidiaries-which-have-shareholders-outside-the-tax-group/127 "2024-09-23T10:13:23Z")

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All income of Tax Group members is included in the Tax Group’s taxable income, unless specified otherwise. This means that any income realized by a Subsidiary must be fully included in the Tax Group’s taxable income (unl…

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## [Under what conditions the expenditure incurred by a Taxable Person's Business deductible, and how does this apply within a Tax Group?](https://uaectfaqs.com/t/under-what-conditions-the-expenditure-incurred-by-a-taxable-persons-business-deductible-and-how-does-this-apply-within-a-tax-group/126)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:12am UTC](https://uaectfaqs.com/t/under-what-conditions-the-expenditure-incurred-by-a-taxable-persons-business-deductible-and-how-does-this-apply-within-a-tax-group/126 "2024-09-23T10:12:47Z")

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Expenditure which is incurred wholly and exclusively for the purposes of a Taxable Person’s Business which is not capital in nature is deductible. For a Tax Group, the assessment of whether expenditure meets this criter…

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## [How Ownership Changes and Business Continuity affects the Carry Forward of Tax Losses in tax group?](https://uaectfaqs.com/t/how-ownership-changes-and-business-continuity-affects-the-carry-forward-of-tax-losses-in-tax-group/125)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:12am UTC](https://uaectfaqs.com/t/how-ownership-changes-and-business-continuity-affects-the-carry-forward-of-tax-losses-in-tax-group/125 "2024-09-23T10:12:14Z")

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A Tax Loss can be carried forward by a Taxable Person under the following conditions: Ownership Condition: The owners of the Taxable Person shall maintain at least 50% ownership from the start of the period in which t…

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## [Kindly explain the application of qualifying group relief to Tax Group?](https://uaectfaqs.com/t/kindly-explain-the-application-of-qualifying-group-relief-to-tax-group/124)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:07am UTC](https://uaectfaqs.com/t/kindly-explain-the-application-of-qualifying-group-relief-to-tax-group/124 "2024-09-23T10:07:59Z")

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A Taxable Person may choose not to account for gains or losses on transfers within a Qualifying Group. This election to be made while filing the Tax Return for the period in which the transfer occurs and is irrevocable. …

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## [How to determine Participation exemption requirement at the tax group level?](https://uaectfaqs.com/t/how-to-determine-participation-exemption-requirement-at-the-tax-group-level/123)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:07am UTC](https://uaectfaqs.com/t/how-to-determine-participation-exemption-requirement-at-the-tax-group-level/123 "2024-09-23T10:07:40Z")

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For the purposes of the Participation Exemption, the determination of whether the Tax Group holds a 5% or greater ownership interest in the shares or capital is based on the combined ownership interests of all members wi…

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## [What are the circumstances under which a tax group shall cease to exist and what shall be the date of dissolution?](https://uaectfaqs.com/t/what-are-the-circumstances-under-which-a-tax-group-shall-cease-to-exist-and-what-shall-be-the-date-of-dissolution/122)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:06am UTC](https://uaectfaqs.com/t/what-are-the-circumstances-under-which-a-tax-group-shall-cease-to-exist-and-what-shall-be-the-date-of-dissolution/122 "2024-09-23T10:06:10Z")

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Circumstance Date from which Tax Group is dissolved If there are only two members of the Tax Group, and one of them transfers its entire Business to the other and ceases to exist as a result of the transfer. T…

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## [Can parent company of a Tax group can be changed/replaced?](https://uaectfaqs.com/t/can-parent-company-of-a-tax-group-can-be-changed-replaced/121)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 10:03am UTC](https://uaectfaqs.com/t/can-parent-company-of-a-tax-group-can-be-changed-replaced/121 "2024-09-23T10:03:38Z")

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The Parent Company of a Tax Group may submit an application to the FTA to be replaced by another Parent Company without a discontinuation of the Tax Group in following circumstances: The new Parent Company meets all the…

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## [What happens if subsidiary member of the tax group transfer its entire business? Also explain the treatment of Gain/ (Loss) arise on such transfer](https://uaectfaqs.com/t/what-happens-if-subsidiary-member-of-the-tax-group-transfer-its-entire-business-also-explain-the-treatment-of-gain-loss-arise-on-such-transfer/120)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:02am UTC](https://uaectfaqs.com/t/what-happens-if-subsidiary-member-of-the-tax-group-transfer-its-entire-business-also-explain-the-treatment-of-gain-loss-arise-on-such-transfer/120 "2024-09-23T10:02:57Z")

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If a Subsidiary transfers all of its Business to another member of the Tax Group, the Subsidiary shall be considered to leave the Tax Group on the date it transfer its entire business to other members and ceases to exist…

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## [Can any member of subsidiary can leave the tax group after formation of the group?](https://uaectfaqs.com/t/can-any-member-of-subsidiary-can-leave-the-tax-group-after-formation-of-the-group/74)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 1\
**Last updated:** [September 10, 2024, 5:43am UTC](https://uaectfaqs.com/t/can-any-member-of-subsidiary-can-leave-the-tax-group-after-formation-of-the-group/74 "2024-09-10T05:43:00Z")

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Can any member of subsidiary can leave the tax group after formation of the group?

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## [How a subsidiary can join an existing Tax Group?](https://uaectfaqs.com/t/how-a-subsidiary-can-join-an-existing-tax-group/119)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:01am UTC](https://uaectfaqs.com/t/how-a-subsidiary-can-join-an-existing-tax-group/119 "2024-09-23T10:01:10Z")

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A Subsidiary can join an existing Tax Group by submitting an application to the FTA by the Parent Company and the relevant Subsidiary if the conditions of Article 40(1) of the Corporate Tax Law are satisfied. The applica…

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## [What types of changes can take place in relation to a Tax Group?](https://uaectfaqs.com/t/what-types-of-changes-can-take-place-in-relation-to-a-tax-group/118)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:00am UTC](https://uaectfaqs.com/t/what-types-of-changes-can-take-place-in-relation-to-a-tax-group/118 "2024-09-23T10:00:40Z")

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The following changes can take place in relation to a Tax Group: Forming a Tax Group; Joining a Tax Group; Leaving a Tax Group; Replacing a Parent Company; and Ceasing to be a Tax Group

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## [When tax group can apply for Deregistration?](https://uaectfaqs.com/t/when-tax-group-can-apply-for-deregistration/117)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
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**Last updated:** [September 23, 2024, 10:00am UTC](https://uaectfaqs.com/t/when-tax-group-can-apply-for-deregistration/117 "2024-09-23T10:00:02Z")

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A Taxable Person can file a Tax Deregistration application in case of a cessation of its Business or Business Activity. In the case of a Tax Group, the question of whether the Business or Business Activity has ceased sh…

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## [Will the 0% CT rate threshold apply to the Tax Group as a whole?](https://uaectfaqs.com/t/will-the-0-ct-rate-threshold-apply-to-the-tax-group-as-a-whole/73)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 1\
**Last updated:** [September 10, 2024, 5:42am UTC](https://uaectfaqs.com/t/will-the-0-ct-rate-threshold-apply-to-the-tax-group-as-a-whole/73 "2024-09-10T05:42:38Z")

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Will the 0% CT rate threshold apply to the Tax Group as a whole?

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## [Explain the procedure to form a tax group in UAE](https://uaectfaqs.com/t/explain-the-procedure-to-form-a-tax-group-in-uae/116)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 9:47am UTC](https://uaectfaqs.com/t/explain-the-procedure-to-form-a-tax-group-in-uae/116 "2024-09-23T09:47:59Z")

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The Parent Company and each Subsidiary seeking to join the tax group must jointly submit an application to the Federal Tax Authority (FTA). The application should clearly specify the following: The names and tax identi…

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## [Will the consolidated financial statements of a Tax Group need to be audited for CT purposes?](https://uaectfaqs.com/t/will-the-consolidated-financial-statements-of-a-tax-group-need-to-be-audited-for-ct-purposes/70)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 1\
**Last updated:** [September 10, 2024, 5:41am UTC](https://uaectfaqs.com/t/will-the-consolidated-financial-statements-of-a-tax-group-need-to-be-audited-for-ct-purposes/70 "2024-09-10T05:41:29Z")

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Will the consolidated financial statements of a Tax Group need to be audited for CT purposes?

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## [Will the Tax Group need to prepare consolidated financial statements?](https://uaectfaqs.com/t/will-the-tax-group-need-to-prepare-consolidated-financial-statements/69)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 1\
**Last updated:** [September 10, 2024, 5:41am UTC](https://uaectfaqs.com/t/will-the-tax-group-need-to-prepare-consolidated-financial-statements/69 "2024-09-10T05:41:08Z")

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Will the Tax Group need to prepare consolidated financial statements?

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## [Will a member of the tax group can change its tax period (Financial year) to join tax group?](https://uaectfaqs.com/t/will-a-member-of-the-tax-group-can-change-its-tax-period-financial-year-to-join-tax-group/115)

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**Author:** [@FAME](https://uaectfaqs.com/u/FAME)\
**Replies:** 0\
**Last updated:** [September 23, 2024, 9:45am UTC](https://uaectfaqs.com/t/will-a-member-of-the-tax-group-can-change-its-tax-period-financial-year-to-join-tax-group/115 "2024-09-23T09:45:34Z")

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Yes, if a juridical Resident Person meets all the conditions for forming or joining a Tax Group except for the Financial Year condition, that person can make an application to the FTA to change the start and end date of …

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