Article commentary and official references

Accounting

Article 21 — Equity-investment inclusion election

Governs an election to include gains, losses and certain taxes relating to non-qualifying equity investments in the computation.

Short answer

Governs an election to include gains, losses and certain taxes relating to non-qualifying equity investments in the computation.

What should you do now?Classify each interest and establish holding period and book and tax treatment before the election.

Provision in brief

What does the official Article provide?

The official source is Arabic. This English commentary is explanatory and is not presented as an official translation.

Governs an election to include gains, losses and certain taxes relating to non-qualifying equity investments in the computation.

This is a verified summary rather than a verbatim reproduction. Consult the official Arabic text, the Law and later decisions before making a final determination.

Madar explanation

What does the Article mean in plain language?

The equity investment election addresses specified ownership results and their associated current and deferred taxes together. Portfolio holdings are excluded and the Paragraph B election lasts five years. Qualified interests in transparent entities have separate rules tracking tax benefits, reducing the investment to zero and treating later receipts subject to caps. The Paragraph M proportional-amortisation election must be made in the acquisition or first in-scope year and is irrevocable. Distinguish that permanent election from the five-year election and avoid including taxes while excluding the corresponding income without a specific rule.

Who should read this?

Financial reporting, tax, transfer-pricing and consolidation teams.

Practical action

Classify each interest and establish holding period and book and tax treatment before the election.

Common mistake to avoid

Confusing the two elections or ignoring the investment balance when recognising flow-through benefits.

Legislative connection

Related Articles

Limits of the commentary

Before relying on the result

Is this Article enough on its own?

Usually not. Read it with the connected Law Article, definitions, any effective election and current NBR guidance, especially for an amount or deadline.

Does NBR guidance replace the Regulations?

No. Guidance explains application and supports procedures and examples, but current legislation and decisions prevail in case of inconsistency.

References

Official sources