Definition
For VAT, Article 1 of Federal Decree-Law No. 8 of 2017 defines a Tax Group as two or more persons registered with the FTA as a single taxable person. Article 14(1) requires each member to have a place of establishment or fixed establishment in the UAE, the members to be related parties, and one or more of them to control the others. Article 9 of the Executive Regulation includes a 50% voting interest test among the ways to show control.
For corporate tax, Article 40 of Federal Decree-Law No. 47 of 2022 requires the parent to hold at least 95% of the share capital of each subsidiary, directly or indirectly, along with 95% of voting rights and profit entitlement.