FTA Updates Tax Groups Guide CTGTGR1: What UAE Groups Should Check

On 11 November 2026 the Federal Tax Authority published an updated Corporate Tax Guide on Tax Groups, CTGTGR1, on its Corporate Tax guides and references page (entry “Tax Groups | CTGTGR1”). The guide page and CTGTGR1 PDF replace the January 2024 version. It is Article 40 guidance, not a new law, and not a VAT tax group (see MoF Decision 197 of 2026 on VAT groups and e-invoicing). See also the tax group and Corporate Tax primers before a 2025 return or grouping decision.

What still has to be true to form a Corporate Tax group?

Section 4 restates Article 40(1): juridical Resident Persons, not Exempt Persons or Qualifying Free Zone Persons, the same Financial Year and Accounting Standards, and at least 95% of share capital, voting rights, and profits and net assets, held for the whole Tax Period. The FTA must approve a joint EmaraTax application (section 5.1). Members are jointly and severally liable (section 5.3).

Section 4.1 (Cabinet Decision No. 63 of 2025): an Unincorporated Partnership approved as a Taxable Person in its own right under Article 16(8) may form or join a Tax Group if those 95% tests are met. One that is not so approved still cannot.

What changes for 2025 returns and grouping decisions?

Aggregated Financial Statements (section 8.2). Taxable Income comes from standalone IFRS or IFRS for SMEs figures, intra-group eliminations and a special-purpose audit (Ministerial Decision No. 84 of 2025 and FTA Decision No. 7 of 2025). Audited aggregated statements are generally due within nine months of period end (section 8.1). The parent files and pays on that same clock (section 5.2).

Pre-grouping Tax Losses and Net Interest Expenditure (sections 10.2 and 11.2). Under Ministerial Decision No. 301 of 2024, if the group can use a member’s pre-grouping Tax Losses or NIE and chooses not to, those amounts can be forfeited (sections 10.2.2 and 11.2.2).

Elections sit at group level. Fair-value Investment Property depreciation (Ministerial Decision No. 173 of 2025, section 8.4.5.3) is elected by the Tax Group, including joiners and leavers. Foreign Tax Credits for periods starting on or after 1 January 2025 use aggregated results (section 12.1). Liquidation losses (section 8.6, Ministerial Decision No. 302 of 2024) and foreign PE / Participation limits (sections 12.2.3 and 12.2.4) apply if those facts exist.

What should owners of small UAE groups check now?

First, confirm 95% on all three ownership tests for the whole 2025 period, and that no member is a Qualifying Free Zone Person. Each company still registers for Corporate Tax until a group is approved.

Second, make intra-group invoices, loans and transfers easy to eliminate. Keeping each entity’s books complete in Naqood makes aggregation easier, because the parent builds from standalone figures.

Third, list pre-grouping losses and NIE, fair-value investment property, and any foreign PE losses or foreign tax before you tick 2025 elections.

FAQ

Does the November 2026 guide change the 95% ownership test?

No. Section 4 still requires 95% of share capital, voting rights, and profits and net assets. Section 4.1 only adds approved Unincorporated Partnerships (Cabinet Decision No. 63 of 2025).

When are a Tax Group’s aggregated financial statements due?

Section 8.1: no later than nine months from the end of the Tax Period, or another date the FTA sets. The parent’s Tax Return and payment use the same window (section 5.2).

Can we ignore pre-grouping losses and use them later?

Not safely. Sections 10.2.2 and 11.2.2 (Ministerial Decision No. 301 of 2024) say they can be forfeited where the group could have used them and does not.

Sources

• FTA, Corporate Tax Guide on Tax Groups, CTGTGR1 (PDF), November 2026
• FTA, Corporate Tax guides and references (CTGTGR1 listing)
• FTA, Tax Groups, CTGTGR1

This post is for general information and does not constitute tax or legal advice. For how the rules apply to your specific situation, consult a qualified UAE tax adviser. Naqood is an FTA-accredited accounting platform for UAE businesses.