14 July 2026 · 95% Test
The 95% Ownership Test Explained
To form a UAE Tax Group, the parent must hold at least 95% of three things in each subsidiary: share capital, voting rights, and entitlement to profits and net assets. The holding can be direct or indirect through other group companies. If any one of the three tests falls below 95%, the subsidiary cannot be included, and the group is not valid for that member.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
All three must hit 95%
It is not enough to own most of the shares.
- 95% of share capital.
- 95% of voting rights.
- 95% of profit and net-asset entitlement.
- Fail one and the member is out.
Direct or indirect
Chains of ownership count.
- Direct holding by the parent.
- Indirect holding via other members.
- Combine chains to reach 95%.
- Document the ownership structure.
Related guides
Frequently Asked Questions
For structures near the 95% line.
Is 90% ownership enough for a tax group?
No. The parent must hold at least 95% of capital, voting rights and profit entitlement of each subsidiary.
Does indirect ownership count?
Yes. The 95% can be held directly or indirectly through other group companies.
What if only voting rights are below 95%?
All three tests must be met; if voting rights are below 95%, the member cannot be grouped.
Can Exiloz test our ownership?
Yes. We map your structure and confirm whether the 95% link is met.
Do you meet 95%?
Exiloz maps your ownership and confirms the 95% test for each subsidiary.