UAE Domestic Minimum Top-up Tax: What MNE Groups Owe and When

The UAE domestic minimum top-up tax is the biggest UAE tax development since VAT arrived in 2018, and arguably the more complicated of the two. It is, in effect, the country’s first true UAE multinational tax — a charge aimed squarely at the largest global groups rather than ordinary domestic businesses. It was enacted through Federal Decree-Law No. 60 of 2023, which amended the Corporate Tax Law to enable Pillar Two, and brought into operational effect by Cabinet Decision No. 142 of 2024. For multinational enterprises operating in the UAE whose consolidated group revenues clear EUR 750 million, it imposes a hard 15 percent effective tax rate floor on UAE profits for fiscal years beginning on or after 1 January 2025. The 0 percent qualifying free zone person rate offers no shelter. The first Top-up Tax Returns are now approaching. This guide explains how the DMTT works, who it catches, how the liability is calculated, and what in-scope groups must do before the penalty grace period runs out. If you would rather have the calculation and filing handled for you, our corporate tax services in the UAE support MNE groups through DMTT scoping, ETR modelling and Top-up Tax Return preparation; for the full step-by-step GloBE mechanics, read the companion DMTT UAE Pillar Two deep-dive.

What the DMTT actually does

The UAE domestic minimum top-up tax is the UAE’s domestic implementation of the OECD Pillar Two Global Anti-Base Erosion (GloBE) rules — the global minimum tax framework agreed by 140+ jurisdictions through the OECD Inclusive Framework on BEPS. Its legal architecture rests on three instruments:

• Federal Decree-Law No. 60 of 2023 — amended the Corporate Tax Law to create the DMTT framework
• Cabinet Decision No. 142 of 2024 — issued 31 December 2024; sets the operational rules, thresholds, and calculation mechanics
• Ministerial Decision No. 88 of 2025 — formally adopts the OECD Commentary and Administrative Guidance as part of UAE DMTT interpretation

The mechanism is a top-up layer: UAE corporate tax is calculated normally — 9 percent on profits above AED 375,000, 0 percent for qualifying free zone persons (QFZPs), and various reliefs as applicable. The DMTT then tests the resulting effective tax rate on UAE profits against the 15 percent global minimum. If the UAE effective tax rate falls short, a top-up tax bridges the gap.

Calculating the DMTT requires separate workings using OECD GloBE mechanics. It is not a simple adjustment to the corporate tax return. GloBE income and adjusted covered taxes are defined differently from UAE taxable income and corporate tax paid, and the divergence is material.

DMTT sits beside corporate tax, not inside it

The UAE DMTT does not amend Federal Decree-Law No. 47 of 2022 — it sits beside it as a parallel statutory layer. Groups that confuse them, or try to extend the corporate tax return into a DMTT calculation, produce filings the FTA will reject.

Article 3 of the Corporate Tax Law: Scope, Then Top-up

Article 3 of Federal Decree-Law No. 47 of 2022 sets the headline UAE corporate tax rates: 0 percent up to AED 375,000, 9 percent above, and 0 percent on qualifying QFZP income. Federal Decree-Law No. 60 of 2023 added a top-up tax provision empowering the Cabinet to issue subordinate legislation in line with the OECD GloBE framework. Cabinet Decision No. 142 of 2024 is that subordinate legislation. The DMTT is structurally embedded in the Corporate Tax Law but administered as a separate registration, return, and payment cycle on EmaraTax.

Cabinet Decision 142/2024: Operationalising Pillar Two

Cabinet Decision 142 of 2024 is a comprehensive 70-plus article instrument domesticating the OECD GloBE Model Rules almost verbatim. Article 3 of the Cabinet Decision defines the computation of Pillar Two Income or Loss — financial accounts follow the accounting standards used for the UPE’s consolidated financial statements (typically IFRS). Subsequent articles cover Adjusted Covered Taxes, the ETR calculation, SBIE, top-up tax computation, transitional safe harbours, and administrative provisions.

Sequencing: Corporate Tax Return Then DMTT Return

In-scope groups run two compliance cycles in parallel. The corporate tax return is due within 9 months of fiscal year-end (30 September 2026 for FY 2025 calendar-year groups). The DMTT Return is due within 15 months (or 18 for the first transition year), so 30 June 2027 for the same group. The corporate tax return determines UAE corporate tax paid, which feeds the Adjusted Covered Taxes line. Finalise the CT return before locking the DMTT numbers — but draft the DMTT working in parallel through the year.

Who’s in scope?

In-scope: MNEs operating in the UAE above the revenue threshold

The DMTT applies to UAE constituent entities of MNE groups with consolidated annual revenues equal to or exceeding EUR 750 million in at least two of the four fiscal years immediately preceding the relevant fiscal year. This “two-of-four test” aligns precisely with the OECD Pillar Two scope.

The two-of-four test does not require consecutive years, which catches people out. A group with EUR 800M revenue in 2021, EUR 700M in 2022, EUR 720M in 2023, and EUR 900M in 2024 is in scope for 2025 — because 2021 and 2024 both cleared the threshold, and that’s all it takes. Reassess every year; scope status drifts as group revenues move.

The EUR 750M threshold is converted to reporting currency using the average December exchange rate for the year before the tested fiscal year. Approximate equivalents: AED 3.15 billion and USD 869 million — but the exact figure depends on the specific year’s exchange rate.

Restructuring carries its own threshold rules. A merger requires the predecessor group revenues to be combined for post-merger threshold testing, while a demerger applies look-back rules using predecessor entity revenue. Both exist to stop groups manipulating the threshold through corporate restructuring.

The EUR 750M Threshold: Mechanics, Restructuring and Currency

“Revenue” tracks the IFRS top-line definition — gross revenue from contracts with customers, plus other operating revenue flowing through the consolidated income statement before cost of sales. Two adjustments commonly trip groups up.

The first is currency conversion. Where the UPE reports in a currency other than euro, the EUR 750M threshold is converted using the average exchange rate for the December immediately preceding the fiscal year being tested. A group reporting in USD that hovers around USD 850M should re-test the threshold each year using the actual December average rate — small currency movements can flip scope on the margin.

The second is restructuring mechanics. Where two groups merge mid-period, the threshold test in the year of the merger takes the combined revenue of both predecessor groups for each relevant prior year. Where a group demerges, each resulting group applies a look-back using the proportionate share of predecessor revenue. The rule prevents groups carving themselves below the threshold through internal reorganisation — a UAE subsidiary emerging from a demerger can be in scope from day one.

A subtler point: the threshold is tested at the group consolidation level, not the UAE sub-consolidation level. A multinational with EUR 50M of UAE revenue but EUR 900M of global revenue is fully in scope for the UAE DMTT on its UAE constituent entities — including QFZP free zone holding companies whose standalone revenue is a fraction of the global figure.

Out of scope

• Purely domestic UAE companies (no overseas presence)
• MNE groups below the EUR 750 million threshold
• Groups in the initial phase of international activity (time-limited exclusion, subject to conditions)

Excluded entities within in-scope groups

Even where a group is in scope, certain UAE constituent entities are excluded from DMTT:

Running the DMTT calculation, end to end

Calculating the domestic minimum top-up tax (DMTT) follows five distinct steps, each using GloBE-defined mechanics that diverge from standard UAE corporate tax calculations. Both must be run in parallel — the corporate tax working does not substitute for the DMTT calculation.

Step 1: Calculate UAE GloBE Income

Start with the constituent entity’s net financial accounting income per consolidated reporting standards. Apply GloBE adjustments: add back covered taxes, remove dividend income meeting GloBE conditions, remove equity gains and losses, remove pre-GloBE deferred tax items, and apply the remaining adjustments specified in the GloBE rules. The result — UAE GloBE Income — will differ from UAE taxable income.

Step 2: Calculate Adjusted Covered Taxes

Adjusted Covered Taxes include UAE corporate tax actually paid or accrued, certain creditable withholding taxes treated as covered taxes under GloBE rules, and adjustments for deferred tax movements. Covered taxes form the numerator of the ETR calculation — precise identification of what counts as a covered tax directly determines whether the UAE ETR clears the 15 percent floor.

Step 3: Calculate the Effective Tax Rate

UAE ETR = Adjusted Covered Taxes ÷ UAE GloBE Income. The ETR is calculated on a jurisdictional aggregate basis — all UAE constituent entities of the group are blended together. A higher-tax UAE entity can partially offset a lower-tax UAE entity within the same blended calculation.

Step 4: Apply the Substance-Based Income Exclusion

The Substance-Based Income Exclusion (SBIE) reduces the GloBE Income subject to top-up tax by amounts tied to genuine UAE economic substance — a defined percentage of eligible payroll costs plus a defined percentage of eligible tangible asset carrying values. SBIE carves genuine substance-driven profit out of the top-up tax base (see the dedicated SBIE section below).

Step 5: Calculate the Top-up Tax

Top-Up Tax Percentage = 15% − UAE ETR. Excess Profit = UAE GloBE Income − SBIE. Top-Up Tax = Top-Up Tax Percentage × Excess Profit.

Why your 9% CT ETR isn’t your GloBE ETR

The work that determines whether a group has any top-up liability sits inside Step 1 and Step 2 — the GloBE income denominator and the Adjusted Covered Taxes numerator. Both diverge from the corresponding UAE corporate tax lines, and the divergences compound.

The ETR Formula in Long Form

Article 5.1 of the OECD GloBE Model Rules — adopted into UAE law via Cabinet Decision 142/2024 — defines the jurisdictional ETR as:

UAE ETR = Σ Adjusted Covered Taxes (UAE CEs) ÷ Net GloBE Income (UAE jurisdiction)

If below 15 percent, the Top-up Tax Percentage equals 15 percent minus the ETR, applied to Excess Profit (GloBE Income less SBIE).

GloBE Income vs Accounting Income

GloBE Income starts from Financial Accounting Net Income or Loss — pre-consolidation. The rules then require headline adjustments: add back net taxes expense; strip out excluded dividends and excluded equity gains on qualifying ownership stakes; reverse policy-disallowed expenses (illegal payments, fines above EUR 50,000); reverse prior-period errors flowing through retained earnings.

Two adjustments matter disproportionately for UAE groups. The stock-based compensation election allows GloBE income to track tax deductions rather than accounting expense — material for UAE entities of US-listed groups. The arm’s length adjustment re-casts in-group transaction prices to the arm’s length figure used for tax — the interaction with UAE transfer pricing documentation is direct.

Adjusted Covered Taxes: What Counts

Covered Taxes are taxes on income or profits — UAE corporate tax qualifies; certain withholding taxes on dividends and royalties qualify. Non-income taxes do not: UAE VAT, customs duties, social security, and excise are all excluded.

The starting figure is then adjusted for the deferred tax adjustment amount (subject to the 15 percent recast cap and the five-year recapture rule), GloBE-eligible push-down taxes, and uncertain tax positions not yet recognised. The 15 percent recast cap is where most UAE groups uncover surprises — a deferred tax asset booked at 9 percent does not give one-for-one DMTT relief.

Jurisdictional Blending

The ETR is calculated on a jurisdictional aggregate basis. All UAE constituent entities blend into a single UAE numerator and denominator. A mainland UAE entity paying 9 percent on AED 50M (AED 4.5M covered tax) and a free zone holding company paying 0 percent on AED 100M blend to a 3 percent jurisdictional ETR on AED 150M of combined GloBE income. Blending buys some relief where higher-tax UAE entities partially offset the zero-tax free zone ones, but it does nothing once the free zone pool is large enough to pull the whole blend below the floor regardless.

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A UAE corporate tax ETR of 9 percent rarely translates to a GloBE ETR of 9 percent. By the time the GloBE income denominator has been expanded and the deferred tax cap has bitten, the GloBE ETR typically lands one to three percentage points lower.

Thresholds and rates at a glance

Where genuine substance pays off through the SBIE

The SBIE is the most operationally important relief within the DMTT framework. It directly reduces the Excess Profit subject to top-up tax, and its value depends on the scale of genuine UAE economic substance the constituent entity maintains.

Two components

1. Payroll Component — a defined percentage of eligible UAE payroll costs, including salaries, benefits, and employer-side contributions for UAE-based employees and qualifying independent contractors
2. Tangible Asset Component — a defined percentage of the carrying value of eligible UAE tangible assets: property, plant and equipment, natural resources, rights to use immovable property, and land

Phase-down schedule

[[chart:sbie-phase-down]]

Strategic note for free zone holding companies: QFZP entities within large MNE groups face the sharpest DMTT exposure. Their 0 percent rate drives the GloBE ETR well below 15 percent. SBIE is the primary planning lever here. Substance investments (UAE hiring, UAE asset acquisition) that already generate positive economic return may also produce material SBIE-driven DMTT savings. Model both dimensions together from the start.

One UAE entity files for the rest — the DDFE

Article 8 of Cabinet Decision 142/2024 imposes a default filing obligation on every UAE Constituent Entity, Joint Venture, and JV Subsidiary. Without intervention, a group with ten UAE constituent entities would file ten separate DMTT Returns. The Cabinet Decision provides a consolidation mechanism: the Domestic Designated Filing Entity (DDFE) election.

Who Can Be Designated

The DDFE must itself be a UAE Constituent Entity (or, for a JV group, a JV Group member). It does not need to be the largest or holding entity — what matters is administrative capacity to gather data, perform the calculations, and interface with the FTA on EmaraTax. In practice, groups choose the UAE regional headquarters or the entity already designated as the corporate tax group parent under UAE corporate tax grouping rules.

How the Election Is Made on EmaraTax

The election is made through the Pillar Two registration workflow on EmaraTax. During registration, the designated entity flags itself as the DDFE and lists the constituent entities it will file for. Other constituent entities still register but their registration links to the DDFE. The election must be made before the first DMTT Return is due — there is no retrospective cure for missed individual filings.

What Happens if No Election Is Made

Without a DDFE, every UAE constituent entity must register, file, and pay independently. For a large group this is costly and creates reconciliation risk: the jurisdictional ETR is a single number, but ten separate returns must reconcile to the consolidated jurisdictional position. The FTA expects internal consistency across the group’s filings.

Joint and Several Liability

The DDFE mechanism consolidates the filing — it does not transfer the underlying liability. Every UAE constituent entity remains jointly and severally liable for the DMTT attributable to UAE operations. If the DDFE files but fails to pay, the FTA can pursue any in-scope UAE constituent entity. In-group indemnification arrangements are sensible governance — they do not bind the FTA but govern internal recovery if collection lands on a non-DDFE entity.

Where the UAE follows OECD GloBE and where it doesn’t

Cabinet Decision 142/2024 domesticates the GloBE rules with high fidelity, but the UAE has made deliberate choices about which parts of the framework to implement. Understanding the alignment and divergence points matters for any group operating in multiple Pillar Two jurisdictions.

What the UAE Tracks From the OECD Model

The substantive calculation mechanics — GloBE Income, Adjusted Covered Taxes, the ETR formula, the SBIE, the Transitional CBCR Safe Harbour, the De Minimis Exclusion — all track the OECD Model Rules and the Consolidated Commentary issued in April 2024. Ministerial Decision 88/2025, issued on 28 March 2025, formally adopted the OECD Commentary and Agreed Administrative Guidance up to January 2025 as binding interpretive guidance. The UAE has not paraphrased the Commentary; it has incorporated the OECD text wholesale. For groups operating Pillar Two compliance frameworks in other QDMTT jurisdictions, the UAE technical calculation should slot in with minimal re-engineering.

Where the UAE Deliberately Diverges: No IIR, No UTPR

The most consequential divergence is what the UAE has not implemented. Pillar Two contemplates three interlocking charging mechanisms — the QDMTT, the Income Inclusion Rule (IIR), and the Undertaxed Profits Rule (UTPR). The UAE has implemented only the QDMTT. The Ministry of Finance’s published rationale is that the UAE Corporate Tax regime does not include a CFC framework, and an IIR sits more naturally alongside one. Practically, UAE-headquartered MNE groups do not collect top-up tax on low-taxed foreign subsidiaries through UAE law — collection happens in other jurisdictions where intermediate parents or sister companies sit.

QDMTT Safe Harbour Status

On 25 August 2025, the UAE DMTT received OECD Transitional Qualified Status, formally meeting the QDMTT Safe Harbour conditions. This is the multilateral recognition that UAE collection extinguishes the GloBE liability on UAE-sourced income — preventing parallel top-up collection by an IIR or UTPR jurisdiction on the same profits. Without the Safe Harbour, a UAE QFZP subsidiary could pay UAE DMTT and then face a parallel IIR charge in the UPE jurisdiction. The Safe Harbour eliminates that double-charge risk for groups that file correctly.

Commentary Adoption: A Living Document

Ministerial Decision 88/2025 adopted the OECD Commentary up to January 2025. The OECD continues to issue Administrative Guidance — further packages in 2025 and 2026 cover deferred tax accounting, blending issues, and the GloBE Information Return template. Expect further Ministerial Decisions to extend UAE adoption. The compliance discipline is to track OECD releases, monitor for the matching UAE adoption decision, and update internal DMTT models when the UAE position shifts.

Filing deadlines and the grace-period catch

[[chart:dmtt-filing-timeline]]

The designated filing entity option: MNE groups may designate a single UAE constituent entity to file the DMTT Return on behalf of the entire UAE group. This consolidates filings, simplifies FTA interactions, and avoids each entity filing separately. Designation must be set up deliberately — it does not apply automatically.

Example: a QFZP inside a EUR 750M+ group

Scenario: A qualifying free zone entity is a constituent of an MNE group that exceeds EUR 750M consolidated revenue. The entity pays 0% corporate tax on its qualifying income. For fiscal year 2025:

SBIE calculation (2025 rates: 9.6% payroll / 7.6% tangible assets):

Top-up tax calculation:

The entity owes AED 16.86 million in UAE domestic minimum top-up tax for FY 2025 — payable alongside the DMTT Return by 30 June 2027. Increasing UAE payroll or tangible asset investment in 2026 would grow the SBIE and directly reduce this liability.

Example: UAE parent, Cayman and BVI subs

The first example shows the UAE collecting DMTT on its own profits. The second illustrates the corollary: because the UAE has no IIR, a UAE-headquartered group does not collect top-up tax through UAE law on low-taxed foreign subsidiaries. Collection happens elsewhere.

Scenario: UAEParentCo is the UPE of an MNE group with EUR 1.2 billion of consolidated revenue. It owns three operating subsidiaries through a Netherlands intermediate holding company, NLHoldCo:

• UAEOpCo — UAE mainland; AED 80M GloBE income; UAE CT of AED 7.2M (9%); UAE ETR 9%
• CaymanCo — Cayman Islands financing sub; EUR 40M GloBE income; 0% local tax
• BVITradeCo — BVI trading sub; EUR 25M GloBE income; 0% local tax

Step 1: UAE DMTT on UAEOpCo. UAEOpCo’s jurisdictional UAE ETR of 9% is below the 15% floor. After SBIE reduces Excess Profit to AED 60M, the top-up percentage of 6% produces a UAE DMTT liability of AED 3.6M, filed through the DDFE on EmaraTax by 30 June 2027.

Step 2: Cayman and BVI Profits — Who Collects? Both jurisdictions operate 0% regimes without their own QDMTTs. The UAE has no IIR, so collection falls to NLHoldCo’s jurisdiction (Netherlands) under the Dutch IIR — effective 1 January 2024. As Intermediate Parent Entity above the two low-tax subs, NLHoldCo remits 15% on the combined EUR 65M (less SBIE) to the Dutch tax authority.

Step 3: UTPR as Backstop. Without NLHoldCo, the UTPR — live in most EU jurisdictions and many others from 1 January 2025 — would allocate the top-up across the group’s other in-scope CEs outside the UAE. Groups with simple ownership chains and no IIR-jurisdiction parent face the most fragmented UTPR allocation.

Six things groups get wrong on DMTT

The first is assuming QFZP treatment provides shelter. The 0 percent rate is precisely what opens up the largest DMTT exposure, since the ETR gap to 15 percent is at its widest when corporate tax is zero, and this is the misunderstanding we run into most often among UAE free zone groups inside large MNE structures.

The second is under-applying the two-of-four threshold test. A group that fell below EUR 750M in the most recent year sometimes concludes it’s out of scope, forgetting that two qualifying years anywhere in the prior four-year window is enough. The test needs running annually, and merger or demerger predecessor revenue feeds into it too.

The third is treating the corporate tax return as a DMTT proxy. GloBE income and adjusted covered taxes diverge materially from UAE taxable income and corporate tax paid, so a group can show a 9% UAE corporate tax ETR and still land on a GloBE ETR of 6% once the adjustments run, which produces a DMTT liability the corporate tax return alone would never flag. That’s why the parallel calculation infrastructure isn’t optional.

The fourth is leaving the SBIE unmodelled. For entities with genuine UAE payroll and tangible assets, the SBIE can cut or wipe out the excess profit exposure, and skipping the calculation means overstating the DMTT liability and missing legitimate planning room in the same move.

The fifth is treating the grace period as open-ended permission to do nothing. Reasonable measures is a positive standard, meaning documented action rather than documented inaction, so groups should be assembling their DMTT compliance files during 2026 instead of hoping to reconstruct them in 2027.

The sixth is overlooking the De Minimis and Transitional Safe Harbours. Groups with small UAE operations, even inside very large global structures, may qualify for the De Minimis Exclusion (GloBE revenue below EUR 10M, GloBE income below EUR 1M) or the Transitional CBCR Safe Harbour, which is available for fiscal years starting before 1 January 2027. Testing those reliefs first saves building full DMTT calculations you may not need.

How the DMTT interacts with the rest of the corporate tax file

The DMTT doesn’t run in a vacuum — it sits on top of positions your group is already taking in its ordinary 9% corporate tax return, and three interactions deserve a mid-2026 review.

Interest disallowances raise your ETR. Where the general interest deduction limitation caps net interest at 30% of adjusted EBITDA, disallowed interest increases UAE taxable income and therefore covered taxes — which pushes the jurisdictional effective tax rate up and can shrink or eliminate a top-up. Groups modelling DMTT exposure without modelling their UAE interest limitation rules position are working with the wrong ETR.

Elections that reduce tax cut both ways. Reliefs that lower the 9% liability — including, at the smaller end of a group, an entity claiming UAE small business relief — reduce covered taxes and drag the jurisdictional ETR down. Inside an in-scope group, a relief that saves 9% on one entity can hand 15% back through the top-up. Every election should now be tested at both levels before it’s made.

The audit trail has to hold at both layers. DMTT filings will be reviewed by the same authority, with the same document-request machinery, as ordinary corporate tax — and reconciling GloBE income back to audited financials is exactly the kind of exercise where gaps surface. The document standards and defence sequencing in our FTA tax audit guide apply to DMTT working papers just as much as to VAT files: contemporaneous computation memos, safe-harbour test evidence, and a clean bridge from consolidation to entity-level numbers.

If your group’s in scope, do these seven things

If your group’s consolidated revenues cleared EUR 750 million in two or more of the last four fiscal years, the UAE domestic minimum top-up tax is live for your UAE operations as of 1 January 2025. These are the actions that matter now:

1. Run scope determination. Apply the two-of-four threshold test, identify all UAE constituent entities, and screen for excluded entity categories. Borderline groups need annual reassessment.
2. Build parallel DMTT calculation models. Separate from your corporate tax return — using GloBE-defined mechanics for GloBE income, adjusted covered taxes, and the ETR calculation.
3. Model SBIE. Calculate the Payroll Component and Tangible Asset Component. Identify whether substance investments in UAE payroll or tangible assets produce a positive economic return when the DMTT savings are factored in.
4. Test all available reliefs. De Minimis Exclusion, Transitional CBCR Safe Harbour, Initial Phase of International Activity Exclusion, and Simplified Calculation Relief for international shipping where applicable.
5. Designate a UAE filing entity. Select the entity that will file the DMTT Return and Pillar Two Information Return on behalf of the UAE group.
6. Document reasonable measures contemporaneously. Compliance audit trail — advisors engaged, scoping performed, data captured — built during 2026, not reconstructed after the fact.
7. Calendar the filing deadline. First DMTT Return: 30 June 2027 for calendar-year groups. Subsequent returns: 15 months from fiscal year-end.

The DMTT framework intersects with several related UAE compliance obligations: transfer pricing documentation for intra-group transactions, corporate tax return preparation, free zone corporate tax eligibility, and country-by-country reporting. Groups that treat these as a connected annual compliance cycle, rather than separate annual scrambles, are best placed for the post-grace-period enforcement environment.

For broader context on the UAE’s corporate tax landscape for larger groups, see the UAE tax changes overview for 2026, the Pillar Two DMTT deep-dive, the Corporate Tax Law overview, and the corporate tax grouping rules for additional technical detail.

Velmont Crest’s UAE compliance team provides corporate tax services for UAE SMEs and advisory support for MNE groups navigating DMTT scoping, effective tax rate modelling, SBIE calculation, and Top-up Tax Return preparation. Book a free consultation to discuss your group’s DMTT position.

References:

1. UAE Federal Tax Authority — Official source for DMTT administration, EmaraTax filing procedures, and Pillar Two implementation guidance
2. UAE Ministry of Finance — Cabinet Decision No. 142 of 2024, Ministerial Decision No. 88 of 2025, and Federal Decree-Law No. 60 of 2023
3. OECD GloBE Model Rules and Commentary — Source framework adopted into UAE law via Ministerial Decision 88/2025
4. UAE Government Business Portal — Official guidance on UAE business and tax obligations