GTL Summary:

Article 61 sets out transitional rules for implementing Corporate Tax. It specifies a Taxable Person’s opening balance sheet for tax purposes shall be the closing balance sheet from the financial year preceding their first Tax Period. This opening balance sheet must be prepared in accordance with accounting standards applied in the State and consider the arm's length principle. Critically, it gives early effect to the general anti-abuse rule (GAAR) in Article 50, making it applicable to transactions entered into from the date the Decree-Law was published in the Official Gazette.

Document Type: Tax Law Article
Law: CIT (FDL No 47 of 2022, as amended)
Article Number: 61
Country: 🇦🇪 UAE
Location: Chapter 19 - Transitional Rules
Order: 61
Last updated at: 2025-11-04 11:19:40 UTC

Chapter 19 - Transitional Rules

Article 61 - Transitional Rules

  1. A Taxable Person’s opening balance sheet for Corporate Tax purposes shall be the closing balance sheet prepared for financial reporting purposes under accounting standards applied in the State on the last day of the Financial Year that ends immediately before their first Tax Period commences, subject to any conditions or adjustments that may be prescribed by the Minister.

  2. The opening balance sheet referred to in Clause 1 of this Article shall be prepared taking into consideration the arm’s length principle in accordance with Article 34 of this Decree Law.

  3. For the purposes of Clauses 1 and 2 of this Article, and as an exception to the provisions of Article 70 of this Decree-Law, the provisions of Article 50 of this Decree-Law shall apply to transactions or arrangements entered into on or after the date this Decree-Law is published in the Official Gazette.

  4. The Cabinet may, at the suggestion of the Minister, issue a decision prescribing other transitional measures related to the implementation of this Decree-Law and the application of its provisions.

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