Article commentary and official references

Transitional provisions

Article 92 — Acquirer-basis carrying value

Details carrying-value adjustments for assets transferred after 30 November 2021 and before the transition year, including deferred tax and intra-entity transfers.

Short answer

Details carrying-value adjustments for assets transferred after 30 November 2021 and before the transition year, including deferred tax and intra-entity transfers.

What should you do now?Inventory transfers since 30 November 2021 and reconcile transferor and acquirer values and deferred tax.

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.

Details carrying-value adjustments for assets transferred after 30 November 2021 and before the transition year, including deferred tax and intra-entity transfers.

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 Article governs the acquirer's basis for transfers covered by Law Article 42, considering later capital expenditure, depreciation and the transferor's Transition Year. Covered movements can include deemed transfers within one entity. New deferred tax arising merely from transfer is generally disregarded, with specified exceptions where transfer tax was paid or the alternative condition holds, subject to a Minimum-Rate basis-difference cap. Document transaction timing, both bases and prior tax; an intra-group accounting uplift does not automatically create tax benefit.

Who should read this?

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

Practical action

Inventory transfers since 30 November 2021 and reconcile transferor and acquirer values and deferred tax.

Common mistake to avoid

Creating deferred tax from an internal uplift without the exception evidence and cap.

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