Answer:
Yes. A UAE group of companies may use tax losses from one group company to offset the taxable income of another (Corporate Tax Guide: Tax Groups, CTGTGR1, Section 10; Article 38 of Federal Decree-Law No. 47 of 2022).
Conditions for Loss Utilisation:
• At least 75% direct or indirect ownership between the companies (or common parent).
• Both companies must be UAE-resident juridical persons.
• Neither company can be exempt or a Qualifying Free Zone Person.
• The loss must arise in a Tax Period after the introduction of Corporate Tax.
• Utilisation is capped at 75% of the taxable income of the receiving company in that Tax Period.
Example:
Company A and Company B are part of the same group and meet the 75% ownership test.
• In 2024, Company A incurs a tax loss of AED 1,000,000.
• In 2025, Company B earns taxable income of AED 800,000.
Company B can use up to 75% of its income (AED 600,000) to offset Company A’s tax loss.
The remaining AED 400,000 of Company A’s loss can be carried forward to future years, subject to continued compliance.
If Comp...