19
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FTA
Issuing authority
AI
Cited answers from article text
FTA Corporate Tax Guide CTGBRR1, Business Restructuring Relief (17 April 2024) is one of the rulebooks issued by the Federal Tax Authority. For compliance officers, legal teams, and advisors working under this regime, finding the right article quickly matters. Lexara indexes the full text of FTA guide: Business Restructuring Relief (CTGBRR1, guidance) and makes it searchable two ways: full-text and keyword search for rapid lookup, and AI Explorer for natural-language questions answered with citations to the exact article.
19 articles in 3 chapters, each with a plain-English summary by Arakan. The full text of every article is in the Laws Browser.
CTGBRR1 s 3.1-3.6; CT Law Art 27(1), (4); MD 133/2023 Arts 2-3, 6-7Qualifying transaction and consideration
Business Restructuring Relief applies to entire businesses or independent parts transferred, requiring shares as consideration, with limitations on cash and non-consideration transfers.
CTGBRR1 s 4.1; CT Law Art 27(2)(a)Legal compliance condition
Transfers must comply with all relevant UAE laws, including merger requirements, for Business Restructuring Relief to be valid.
CTGBRR1 s 4.2-4.3; CT Law Art 27(2)(b)-(d), Art 21(2)(b)Taxable Persons, Exempt Person and Qualifying Free Zone Person conditions
Transferors and Transferees must be Resident or Non-Resident Persons with a UAE Permanent Establishment to qualify for Business Restructuring Relief; certain exemptions apply.
CTGBRR1 s 4.4Financial Year condition
The Transferor and Transferee must have aligned Financial Year ends to qualify for Business Restructuring Relief, subject to certain conditions for changing Financial Year ends.
CTGBRR1 s 4.5; CT Law Art 27(2)(f); MD 114/2023 Art 4Accounting Standards condition
Transferor and Transferee must align Financial Statements under the same Accounting Standards, with specific conditions for IFRS and IFRS SMEs.
CTGBRR1 s 4.6, 7.2; CT Law Art 27(2)(g)Valid commercial reasons condition
Transfers must have valid commercial reasons reflecting economic reality, with documentation retained by both transferor and transferee.
CTGBRR1 s 5.1; CT Law Art 27(3)(a); MD 134/2023 Arts 5, 9; MD 133/2023 Art 8(1)Net book value treatment and Transferee adjustments
Transferor gains or losses are not recognized; Transferee must adjust taxable income regarding untaxed gains upon realisation in business restructuring.
CTGBRR1 s 5.2; CT Law Art 27(3)(b)-(c)Value of shares received
The Transferor must value shares received as no more than net book value minus other consideration, affecting later sales.
CTGBRR1 s 5.3; CT Law Art 27(3)(d); MD 133/2023 Art 5Transfer of Tax Losses
Unutilized Tax Losses transfer from the Transferor to Transferee only if the same or similar business is continued post-restructuring.
CTGBRR1 s 5.4; CT Law Arts 34, 20Not electing or not qualifying
If conditions for tax relief are unmet, transfers between Related Parties use arm's length values, while those between unrelated parties follow applicable Financial Statements.
CTGBRR1 s 6; CT Law Art 27(6)Clawback: 2-year test
The Business Restructuring Relief does not apply if shares are transferred outside the Qualifying Group within two years, resulting in a clawback at market value.
CTGBRR1 s 6.1; CT Law Art 27(6)(a), (4); MD 133/2023 Art 6(2)Clawback: share transfers in the two-year window
Share transfers outside a Qualifying Group within two years may trigger clawback provisions under the FTA's Business Restructuring Relief.
CTGBRR1 s 6.2; CT Law Art 27(6)(b)Clawback: subsequent transfer of the Business
A transfer of business within two years triggers clawback provisions, affecting independent parts, operational changes, and other restructuring activities.
CTGBRR1 s 6.3.1; CT Law Art 27(7); MD 133/2023 Art 8(1)-(3)Clawback: Transferor consequences
Clawbacks treat transfers as made at market value on the original date, affecting taxable income for transferors or transferees.
CTGBRR1 s 6.3.2; MD 133/2023 Art 8(4); MD 134/2023 Arts 3, 5Clawback: Transferee consequences
On clawback, the Transferee must reverse previous value changes and adjust values according to Article guidelines during the Tax Period.
CTGBRR1 s 7.1-7.2; Ministerial Decision 133/2023 Art 9Election and records
The Transferor must elect Business Restructuring Relief for each restructuring and keep a record of asset and liability transfers and necessary tax documentation.
CTGBRR1 s 8.1; CT Law Arts 26(4)-(5), 27(6)-(7)Interaction with Qualifying Group Relief
Electing both Qualifying Group Relief and Business Restructuring Relief results in a clawback that affects no gain or loss treatment, as per the FTA guide.
CTGBRR1 s 6; CT Law Art 27(6)-retRecord Retention — Valuation and transfer records for a relieved restructuring
Records for valuation and transfer in a relieved restructuring must be retained for at least the 2-year clawback window starting from the transfer date.
CTGBRR1 s 4.6, 7.2-retRecord Retention — Commercial-reasons documentation and adjustment records
Companies must retain commercial-reasons documentation and adjustment records with transfer records following a business transfer as specified in the FTA guide.
FTA guide: Business Restructuring Relief (CTGBRR1, guidance)'s 36 indexed articles break down by obligation type as follows.
Tax / Finance — 34 articles
General — 2 articles
FTA guide: Business Restructuring Relief (CTGBRR1, guidance) spans the following regulatory topics, as tagged by Lexara.
corporate tax
business restructuring relief
guidance
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fta
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What is FTA Corporate Tax Guide CTGBRR1, Business Restructuring Relief (17 April 2024)?
FTA Corporate Tax Guide CTGBRR1, Business Restructuring Relief (17 April 2024) is issued by the Federal Tax Authority. It has 19 articles across 3 chapters.
What does FTA guide: Business Restructuring Relief (CTGBRR1, guidance) cover?
It is organised into: FTA Business Restructuring Relief guide CTGBRR1; FTA CTGBRR1 s 6; FTA CTGBRR1 s 7.2.
Who issues FTA guide: Business Restructuring Relief (CTGBRR1, guidance)?
The Federal Tax Authority. Always check the authority's official publication for the binding text.
Can I search FTA guide: Business Restructuring Relief (CTGBRR1, guidance) and ask questions about it?
Yes. Lexara searches the full text of all 19 articles and answers plain-English questions with a citation to the exact article.
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