The UAE Ministry of Finance has published Ministerial Decision No. 88 of 2025 on the Commentary and Agreed Administrative Guidance for the Purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax On Multinational Enterprises on 28 March 2025.

The Ministerial Decision update  list attached to Ministerial Decision (88) of 2025 on the Commentary and Agreed Administrative Guidance for the Purposes of Cabinet Decision No. (142) of 2024 on the Imposition of Top-Up Tax On Multinational Enterprises

  1. OECD (2024), Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023): Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris.
  2. OECD (2024), Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), June 2024, OECD/G20 Inclusive Framework on BEPS, OECD, Paris.
  3. OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules –Central Record, OECD/G20 Inclusive Framework on BEPS, OECD, Paris.
  4. OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on Article 8.1.4 and 8.1.5 of the Global Anti-Base Erosion Model Rules (January 2025), OECD/G20 Inclusive Framework on BEPS, OECD, Paris.
  5. OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules, OECD/G20 Inclusive Framework on BEPS, OECD, Paris. 6. OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (January 2025), OECD/G20 Inclusive Framework on BEPS, OECD, Paris.

This Decision was effective from 1 January 2025.

Earlier, the UAE Ministry of Finance published a copy of Cabinet Decision No. 142 of 2024, detailing the country’s Domestic Minimum Top-up Tax (UAE DMTT) law.

The Decision enacted a DMTT for multinational enterprises (MNEs). This measure aligns with the OECD’s Pillar Two framework, establishing a 15% Global Minimum Tax (GMT) for large international corporate groups, effective for financial years beginning on or after 1 January 2025.

Entities subject to the top-up tax include constituent entities, joint ventures, permanent establishments, and minority-owned constituent entities. Government and investment entities are exempt from this requirement.