Решение Федерального налогового органа No7 от 2025 года Об определении требований по подготовке и ведению аудированной финансовой отчетности специального назначения для налоговой группы в целях Федерального декрета-закона No 47 от 2022 года "О налогообложении корпораций и предприятий" и его изменениях

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Federal Tax Authority Decision No. 7 of 2025 – Unofficial translation
This is not an official translation:
Determination of the Requirements for Preparing and
Maintaining Audited Special Purpose Financial Statements for
a Tax Group for the purposes of Federal Decree-Law No. 47 of
2022 on the Taxation of Corporations and Businesses and its
amendments
Federal Tax Authority Decision No. 7 of 2025 - Issued 16 July 2025 - (Effective for tax periods
commencing on or after 1 January 2025)

The Chairman of the Board of Directors of the Federal Tax Authority
has decided:

– Having reviewed the Constitution,
– Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority, and
its amendments,
– Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments,
– Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and
its amendments,
– Cabinet Decision No. 74 of 2023 on the Executive Regulation of Federal Decree-Law No.
28 of 2022 on Tax Procedures,
– Ministerial Decision No. 114 of 2023 on the Accounting Standards and Methods for the
Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and
Businesses,


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Federal Tax Authority Decision No. 7 of 2025 – Unofficial translation
– Ministerial Decision No. 301 of 2024 on Tax Group for the Purposes of Federal Decree-
Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
– Ministerial Decision No. 84 of 2025 on Audited Financial Statements for the Purposes of
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
– Decision of the Chairman of the Board of Directors No. 9 of 2021 on the Delegation to the
Vice Chairman of the Board of Directors of the Federal Tax Authority, and
– Pursuant to the approval of the Board of Directors on the memorandum passed on
11/07/2025 on the Determination of the Requirements for Preparing and Maintaining
Audited Special Purpose Financial Statements for a Tax Group.

Article 1 – Definitions
Words and expressions in this Decision shall have the same meanings specified in the Federal-
Decree Law No. 47 of 2022 referred to above (“Corporate Tax Law”), with the exception of
the following expression which shall have the meaning assigned against it, unless the context
otherwise requires:
Aggregated Financial
Statements
: Financial Statements prepared on the basis of the
aggregation of the standalone Financial Statements of
the Parent Company and each Subsidiary that is a
member of the Tax Group in accordance with the
framework specified in Article 3 of this Decision.

Article 2 – Requirements for Preparing and Maintaining Audited
Special Purpose Financial Statements for a Tax Group
1. For the purposes of Clause 1 of Article 54 of the Corporate Tax Law referred to above, a
Tax Group shall prepare special purpose financial statements in the form of Aggregated
Financial Statements in line with the framework specified in Article 3 of this Decision.


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Federal Tax Authority Decision No. 7 of 2025 – Unofficial translation
2. For the purposes of Clause 2 of Article 54 of the Corporate Tax Law and Clause 2 of Article
2 of Ministerial Decision No. 84 of 2025, the Aggregated Financial Statements of the Tax
Group must be audited under a special purpose framework in accordance with the
relevant International Standards on Auditing (‘’ISA’’).
3. For the purposes of Clause 1 of Article 54 of the Corporate Tax Law, the audited
Aggregated Financial Statements of the Tax Group must be submitted to the Authority no
later than (9) nine months from the end of the relevant Tax Period, or such other date as
determined by the Authority.
Article 3 – Framework for Preparation of Aggregated Financial
Statements
1. For the purposes of preparing the Aggregated Financial Statements, the standalone
Financial Statements of the members of the Tax Group must be aggregated eliminating
transactions between the members.
2. The Aggregated Financial Statements must be prepared annually based on the standalone
Financial Statements of the members of the Tax Group prepared for the relevant Financial
Year.
3. The Aggregated Financial Statements must comply with International Financial Reporting
Standards (“IFRS”) or International Financial Reporting Standards for small and medium-
sized entities (“IFRS for SMEs”), subject to the following provisions:
a. The standalone Financial Statements of an acquiring entity which is a member of a
Tax Group should not reflect the accounting implications of business combinations
under IFRS 3 and consolidated financial statements prepared under IFRS 10 in
relation to such business combinations for the purposes of aggregation of the
financial statements.
b. For the purposes of preparing the Aggregated Financial Statements, the
adjustments relating to goodwill, gain on bargain purchase or fair value
adjustments to assets and liabilities that are recorded in IFRS compliant
consolidated financial statements shall not be recorded in the Aggregated Financial
Statements.


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Federal Tax Authority Decision No. 7 of 2025 – Unofficial translation
c. As an exception to paragraph (b), where business combinations are executed
without the acquisition of a separate legal entity, the resultant assets, liabilities,
goodwill or gain on bargain purchase are part of the separate Financial Statements
of the acquiring entity and are to be aggregated completely into the Aggregated
Financial Statements of the Tax Group.
d. Members of the Tax Group must perform a line-by-line aggregation of Financial
Statement captions, including those relating to investments recorded by the Parent
Company or any Subsidiary, or relating to corresponding equity recorded by the
Subsidiaries within the Tax Group without any eliminations between these
captions.
e. For the purposes of preparing the Aggregated Financial Statements, any
impairment that the Parent Company has recorded over its investment in a
Subsidiary in the Tax Group should not be eliminated where the Parent Company
directly holds the Subsidiary in the Tax Group.
f. For the purposes of preparing the Aggregated Financial Statements, any
impairment that a Subsidiary has recorded over its investment in another
Subsidiary in the Tax Group should not be eliminated where one Subsidiary directly
holds another Subsidiary in the Tax Group.
4. The following principles must be applied in the preparation of Aggregated Financial
Statements:
a. Subject to Clause 3 of this Article, any income, expenses, unrealised gains and
losses, and any other transactions between members of the Tax Group shall be
eliminated.
b. The standalone Financial Statements of entities which are not part of a Tax Group
must not be aggregated as part of the Aggregated Financial Statements of the Tax
Group.
c. Transactions with entities which are not members of the Tax Group must not be
eliminated for the purposes of preparing the Aggregated Financial Statements of
the Tax Group.
d. The standalone Financial Statements of the members of the Tax Group must be
prepared in accordance with IFRS (or IFRS for SMEs).


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Federal Tax Authority Decision No. 7 of 2025 – Unofficial translation
e. The standalone Financial Statements of the members of the Tax Group must be
prepared using uniform accounting policies.
f. The accounting profit or loss that will be aggregated must be the pre-tax profit or
loss of the members of the Tax Group.
g. Investments in subsidiaries, joint ventures and associates that are not members of
the Tax Group must be carried at cost less impairment.
h. The Aggregated Financial Statements of the Tax Group must be presented in the
United Arab Emirates Dirham.
Article 4 – Statements and Disclosure Requirements for Aggregated
Financial Statements Purposes
1. The statements to be presented in a set of Aggregated Financial Statements are:
a. Aggregated statement of financial position.
b. Aggregated statement of profit or loss.
c. Aggregated statement of other comprehensive income.
d. Aggregated statement of changes in equity.
2. The disclosure requirements for the Aggregated Financial Statements should include the
following:
a. The framework under which the Aggregated Financial Statements have been
prepared.
b. The basis of aggregation.
c. The material accounting policies, estimates and judgments based on which the
Aggregated Financial Statements are prepared.
d. The explanatory information and notes that sufficiently support the numbers
presented in the Aggregated Financial Statements.
Article 5 – Financial Statements of Members Leaving the Tax Group
1. For the purposes of Article 13 of Ministerial Decision No. 301 of 2024 referred to above,
where a member leaves the Tax Group or the Tax Group ceases to exist, the member
leaving the Tax Group shall adopt the values of the relevant assets and liabilities as


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Federal Tax Authority Decision No. 7 of 2025 – Unofficial translation
recorded by the Tax Group as the opening values of those assets and liabilities in its
standalone Financial Statements.
2. As an exception to Clause 1 of this Article, if the applicable Accounting Standards do not
permit using such values, the member leaving the Tax Group shall calculate its Taxable
Income as if the Accounting Standards would have allowed using such values.
Article 6 – Implementation of the Decision
This Decision shall be published in the Official Gazette and shall apply to Tax Periods
commencing on or after 1 January 2025.