Article commentary and official references

Transitional provisions

Article 91 — Deferred tax assets or liabilities in the transition year

Governs transition-year deferred tax assets and liabilities at the lower of the minimum rate and recorded rate, with exclusions and remeasurement.

Short answer

Governs transition-year deferred tax assets and liabilities at the lower of the minimum rate and recorded rate, with exclusions and remeasurement.

What should you do now?Retain the prior-year-end deferred-tax schedule, measurement rate and type of each difference.

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 transition-year deferred tax assets and liabilities at the lower of the minimum rate and recorded rate, with exclusions and remeasurement.

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?

At transition, examine opening deferred-tax assets and liabilities at the lower of the Minimum Rate and the recorded rate, recasting where required. A loss asset may be recomputed at the Minimum Rate where evidence shows the original loss would have been a Constituent Entity Loss had the group been in scope. Disregard the specified valuation and recognition adjustments. Document each opening balance's origin, year, rate and loss character rather than copying it from the accounts.

Who should read this?

Groups entering the regime from 2025 and reporting, deferred-tax and acquisition teams.

Practical action

Retain the prior-year-end deferred-tax schedule, measurement rate and type of each difference.

Common mistake to avoid

Recasting every deferred-tax asset to 15% without establishing the qualifying loss.

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