Tax Group Audited Special Purpose Financial Statements — Requirements Under MD 84 of 2025

Tax Groups registered under the UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022) are subject to a distinct financial reporting obligation that differs from the requirements imposed on individual Taxable Persons. Rather than standard audited financial statements, a Tax Group must prepare and maintain audited special purpose financial statements in the specific form, procedures, and rules determined by the Federal Tax Authority. This requirement is set out in Article 2(2) of Ministerial Decision No. 84 of 2025.

What Are Audited Special Purpose Financial Statements?

Special purpose financial statements differ from general purpose financial statements in that they are prepared for a specific audience or purpose — in this case, to satisfy the UAE Corporate Tax compliance requirements for a Tax Group. They consolidate the financial position and results of the Tax Group members in a manner prescribed by the FTA, rather than following the full disclosure requirements of IFRS-based general purpose reporting. They must nevertheless be audited by a licensed auditor.

Legal Basis for the Tax Group Audit Obligation

The obligation derives from the interaction of two provisions:

• Article 54(2) of the Corporate Tax Law — which grants the Minister authority to determine categories of Taxable Persons required to prepare audited financial statements.
• Article 3 of Ministerial Decision No. 114 of 2023 — on accounting standards and methods — which addresses the accounting framework applicable to Tax Groups.

MD 84 of 2025 activates both of these provisions and makes the audit obligation for Tax Groups explicit and enforceable.

How Is a Tax Group Different from Individual Taxable Persons for This Purpose?

Individual Taxable Persons face the AED 50 million revenue threshold (or automatic obligation if they are QFZPs). Tax Groups, by contrast, are not assessed against the revenue threshold at all — they have their own separate and unconditional obligation to produce special purpose statements. The form and content of these statements is defined by the FTA, not purely by IFRS, and is specific to the CT compliance context.

FTA-Prescribed Form and Procedures

The FTA has the authority to prescribe the precise form, procedures, and rules for Tax Group special purpose financial statements. Tax Groups should monitor FTA publications and guidance notes for the specific requirements applicable to their reporting period. The representative member of the Tax Group is typically responsible for coordinating the audit and submitting the required documentation.

Subsidiary Members and Individual Statements

Individual members of a Tax Group may still be required to maintain their own financial records and prepare individual financial statements — particularly if they independently meet other threshold or status requirements (e.g., if an individual member is itself a QFZP with its own audit requirement). The Tax Group special purpose statements operate at the group level and do not necessarily replace all individual member obligations.

Timing and Record Retention

Special purpose financial statements must be prepared for each Tax Period of the Tax Group and retained for the mandatory seven-year period under the Tax Procedures Law. The audit must be completed in time to support the Tax Return filing by the representative member.

How Abdelhamid & Co. Can Help

We provide specialised audit and compliance services for UAE Tax Groups, including preparation of audited special purpose financial statements in the format required by the FTA. Our team advises on Tax Group formation, representative member responsibilities, and the interaction between group-level and entity-level reporting obligations.

Frequently Asked Questions

Last reviewed: May 2025 | Reference: Ministerial Decision No. 84 of 2025