Article commentary and official references

Transitional provisions

Article 93 — Transition year on commencement

Defines the transition year as the first fiscal year beginning on or after 1 January 2025, from which obligations arise subject to anti-avoidance rules.

Short answer

Defines the transition year as the first fiscal year beginning on or after 1 January 2025, from which obligations arise subject to anti-avoidance rules.

What should you do now?Identify the first fiscal-year start on or after 1 January 2025; do not confuse it with year-end or filing date.

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.

Defines the transition year as the first fiscal year beginning on or after 1 January 2025, from which obligations arise subject to anti-avoidance rules.

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 commencement Transition Year is the first Fiscal Year beginning on or after the Law's effective date, not necessarily the calendar year containing that date. Obligations arise from that year's beginning, subject to anti-abuse provisions. Use the group's actual Fiscal-Year start for first returns, advances and opening balances, and distinguish this commencement rule from a later-entering group's Transition Year.

Who should read this?

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

Practical action

Identify the first fiscal-year start on or after 1 January 2025; do not confuse it with year-end or filing date.

Illustrative Madar example

How can the rule appear in practice?

For a group with a 1 July year start, the commencement transition year begins 1 July 2025, not the period that began in July 2024.

This illustration is not an NBR case or a binding outcome for a particular fact pattern.
Common mistake to avoid

Starting computation midway through an existing Fiscal Year solely because the Law becomes effective.

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