31 August 2026 · Scope
What Transfers Qualify
Article 27 relief covers the transfer of a whole business, or an independent part of a business capable of separate operation, in the course of a merger, spin-off or other reorganisation. The transfer is made on a no gain / no loss basis. A transfer of isolated assets that is not a business (or independent part) does not qualify under Article 27, that may instead fall under Qualifying Group Relief.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
Business-level transfers
It is about businesses, not stray assets.
- Transfer of a whole business.
- Transfer of an independent, separable part.
- In a merger, spin-off or reorganisation.
- On a no gain / no loss basis.
What Article 27 is not for
Some transfers need a different relief.
- Isolated assets that are not a business.
- Transfers to exempt persons or QFZPs.
- Transfers lacking commercial substance.
- These may fall under Article 26 or be taxable.
Related guides
Frequently Asked Questions
For scoping your transaction.
Does moving one asset qualify?
Not under Article 27, which covers a whole business or independent part; single-asset moves may fall under Qualifying Group Relief.
What is an independent part of a business?
A part capable of operating separately as a going concern on its own.
Are spin-offs covered?
Yes, spin-offs and other reorganisations that transfer a business or independent part can qualify.
Can Exiloz scope our deal?
Yes. We confirm whether your transaction fits Article 27 or another relief.
Does your transfer qualify?
Exiloz scopes your merger or reorganisation against Article 27.