🇦🇪 Tax11 Feb 2025
UAE introduces a 15% domestic minimum top-up tax for large groups
On 11 February 2025 the UAE Ministry of Finance published Cabinet Decision No. 142 of 2024, which imposes a domestic minimum top-up tax on UAE entities of multinational groups with consolidated revenue of at least EUR 750 million in two of the last four years. It applies for financial years starting on or after 1 January 2025 and tops up their effective tax rate in the UAE to 15%. Detailed rules were published with it.
Federal Decree-Law No. 60 of 2023 amended the UAE's corporate tax law to allow a global minimum tax. Cabinet Decision No. 142 of 2024 brings in the domestic top-up tax.
What changed
- UAE entities of multinational groups with revenue of at least EUR 750 million in two of the last four financial years pay a top-up tax so that their effective rate in the UAE is at least 15%.
- It applies to financial years starting on or after 1 January 2025.
- The rules follow the OECD Pillar Two model rules, commentary and administrative guidance.
- The UAE's standard 9% corporate tax continues for everyone else.
Who is affected
UAE entities of large multinational groups, including free zone entities, and their finance teams.