Pillar Two in the UAE: the 15% Top-up Tax
Who it applies to
The DMTT applies to constituent entities in the UAE of multinational groups whose ultimate parent reports consolidated revenue of €750 million or more in at least two of the four preceding financial years. It follows the OECD GloBE model rules, including a de minimis exclusion under which the top-up tax for an entity can be zero.1,2
The legal basis
- Cabinet Decision No. 142 of 2024 introduced the DMTT for financial years beginning on or after 1 January 2025.
- Ministerial Decision No. 96 of 2026 adopted the OECD commentary and agreed administrative guidance, and Ministerial Decision No. 133 of 2026 set the entities that file the Pillar Two information return.
Source: UAE Ministry of Finance: Cabinet Decision on the Top-up Tax for multinational enterprises; Federal Tax Authority: Cabinet Decision No. 142 of 2024; UAE Ministry of Finance: Financial legislation2,3,4
Sources
- UAE Ministry of Finance: Domestic Minimum Top-up Tax
- UAE Ministry of Finance: Cabinet Decision on the Top-up Tax for multinational enterprises
- Federal Tax Authority: Cabinet Decision No. 142 of 2024 (PDF)
- UAE Ministry of Finance: Financial legislation
Figures checked 21 October 2026. Prepared by Invest-Emirates.ae for general information. It is not investment, tax or legal advice; please confirm details with a qualified adviser before acting.