• A2, Digital Park, Dubai Silicon Oasis, Dubai, UAE
  • Mon - Fri: 8:30 AM - 6:00 PM
Accounting & Tax Advisory Practice

Corporate Tax Planning & Strategic Restructuring

Pre-tax implementation restructuring, holding company optimization, business asset carve-outs, and tax-neutral mergers under UAE law.

Structure your UAE business group for optimal long-term tax efficiency. Expert guidance on Qualifying Group reliefs, business restructuring reliefs, and holding company regimes.

Article 26
Qualifying Group Relief
Tax-neutral intercompany asset transfers
Article 27
Restructuring Relief
Tax-free mergers, spin-offs & demergers
Holding Co.
Participation Exemption
0% tax on dividends & capital gains
Long-Term
Value Creation
Sustainable post-tax shareholder returns

Strategic Tax Structuring under UAE Law

Federal Decree-Law No. 47 of 2022 provides powerful statutory reliefs that allow commercial groups to restructure, merge, or separate business units without triggering immediate corporate tax liabilities. We assist corporate leaders in designing and executing sophisticated restructuring plans that unlock operational efficiencies while maintaining full tax neutrality.

Participation Exemption Advisory

Structuring holding companies to achieve 0% corporate tax on foreign dividends and capital gains from 5%+ shareholdings (Article 23).

Business Restructuring Relief (Article 27)

Executing tax-neutral transfers of whole business undertakings or independent parts in exchange for equity.

Qualifying Group Asset Transfers (Article 26)

Moving real estate, intellectual property, and equipment between group members at net book value with zero tax.

Corporate Tax Group Formation

Consolidating 95%+ owned UAE entities into a single fiscal unity to offset group profits and losses automatically.

Structured Execution & Statutory Roadmap

01
Strategic Group Diagnostic

Analyzing existing legal entities, ownership percentages, asset locations, and commercial objectives.

02
Restructuring Architecture Design

Developing detailed step-by-step restructuring plan outlining legal, commercial, and tax impacts.

03
Relief Election Preparation

Drafting statutory relief election documentation and board resolutions required under UAE tax law.

04
Post-Restructuring Governance

Establishing tracking systems to monitor mandatory 2-year clawback holding periods under Articles 26 and 27.

Mandatory Documentation & Prerequisites

  • Group Equity & Ownership Charts: Detailed shareholding percentages and capital structure across all entities involved.
  • Balance Sheets & Asset Registers: Current book values and market valuations of assets and liabilities to be transferred.
  • Draft Restructuring Plan: Commercial rationale and proposed legal steps for merger, spin-off, or asset transfer.
  • Audited Financial Statements: Historical financial statements demonstrating continuous operational substance.

Maximizing Shareholder Value Legally

Proper tax planning ensures your group structure is resilient, scalable, and optimized for investment, divestment, or generational succession without unmanaged tax friction.

Direct Practice Engagement

Schedule an Advisory Review

Engage directly with certified FTA Tax Agents, MoIAT conformity specialists, and enterprise technology architects.