Starting from January 1, 2025, the Domestic Minimum Top-up Tax (DMTT) applies in UAE for multinational groups meeting the EUR 750 million global revenue threshold.
𝗪𝗵𝘆 𝗱𝗼𝗲𝘀 𝘁𝗵𝗶𝘀 𝗺𝗮𝘁𝘁𝗲𝗿?
Under OECD’s Pillar Two rules, all in-scope UAE entities will be required to pay a minimum 15% effective tax rate.
𝗥𝗮𝘁𝗲: 15%
𝗘𝗳𝗳𝗲𝗰𝘁𝗶𝘃𝗲 𝗳𝗿𝗼𝗺: FY starting on or after Jan 1, 2025
𝗙𝗶𝗹𝗶𝗻𝗴 𝗱𝗲𝗮𝗱𝗹𝗶𝗻𝗲: Within 15 months of financial year-end (first year gets 18 months as per Pillar- 2 transitional rules )
𝗪𝗵𝗼 𝗺𝘂𝘀𝘁 𝗿𝗲𝗴𝗶𝘀𝘁𝗲𝗿: All in-scope UAE constituent entities & JVs
𝗥𝗲𝘁𝘂𝗿𝗻𝘀 𝘁𝗼 𝗳𝗶𝗹𝗲: Top-up Tax Return + Pillar Two Information Return
𝗪𝗵𝗮𝘁 𝗯𝘂𝘀𝗶𝗻𝗲𝘀𝘀𝗲𝘀 𝗺𝘂𝘀𝘁 𝗱𝗼 𝗻𝗼𝘄:
1. Assess eligibility and MNE status
2. Start data mapping for GloBE Income, Adjusted Covered Taxes, ETR
3. Prepare systems to meet reporting and compliance requirements
4. Coordinate globally with parent entities to align data and timing
