31 August 2026 · Conditions
Conditions Both Parties Must Meet
To qualify for Article 27 relief, both the transferor and transferee must be UAE resident (or non-residents with a UAE permanent establishment), share the same financial year and accounting standards, and be neither Exempt Persons nor Qualifying Free Zone Persons. The transfer must be for valid commercial or economic reasons that are not the avoidance of tax. Consideration is typically shares or an ownership interest.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
Who can transfer
Both sides must qualify.
- UAE resident, or non-resident with a UAE PE.
- Same financial year and accounting standards.
- Neither is an Exempt Person.
- Neither is a Qualifying Free Zone Person.
Commercial substance
Tax cannot be the main reason.
- Valid commercial or economic reasons required.
- Not principally for tax avoidance.
- Consideration usually in shares/ownership.
- Document the rationale.
Related guides
Frequently Asked Questions
For confirming both parties qualify.
Can a QFZP use restructuring relief?
No. A Qualifying Free Zone Person cannot be a party to an Article 27 transfer.
Must the parties share a year-end?
Yes, and the same accounting standards.
What are valid commercial reasons?
Genuine business or economic reasons for the transfer, not the avoidance of tax.
Can Exiloz confirm eligibility?
Yes. We test each condition and document the commercial rationale.
Do you meet the conditions?
Exiloz confirms both parties qualify and documents the commercial reasons.