Ministerial Decision No. 96 of 2026 adopts the OECD's latest Commentary and Administrative Guidance for the UAE's domestic Pillar Two regime, repeals the previous guidance and applies to fiscal years beginning on or after 1 January 2025.
The UAE has updated the guidance for its domestic Pillar Two regime by issuing Ministerial Decision No. 96 of 2026 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.
The Decision adopts the OECD’s latest interpretative materials for the application of the UAE’s domestic Pillar Two rules. These include the OECD (2026) Consolidated Commentary to the Global Anti-Base Erosion Model Rules and the OECD (2026) Administrative Guidance on the Global Anti-Base Erosion Model Rules, providing updated guidance on the interpretation and implementation of the regime.
Ministerial Decision No. 96 of 2026 also adopts the OECD (2025) GloBE Information Return (January 2025) as part of the annex accompanying the decision.
It applies to Fiscal Years starting on or after 1 January 2025 and repeals Ministerial Decision No. 88 of 2025, which previously governed the Commentary and Agreed Administrative Guidance for the regime.
Cabinet Decision No. 142 of 2024 introduced the UAE’s qualified domestic minimum top-up tax (QDMTT), referred to as the UAE DMTT, which applies from 1 January 2025 to multinational enterprises within the scope of the Pillar Two rules.
Ministerial Decision No. 96 of 2026 was issued by Mohamed bin Hadi Al Hussaini, Minister of State for Financial Affairs, on 22 June 2026. It takes effect from the date of its issuance.
Earlier, the UAE’s Federal Tax Authority (FTA) activated Pillar Two top-up tax registration on the EmaraTax portal, requiring in-scope multinational enterprise (MNE) groups to begin assessing their registration obligations and preparing the necessary documentation.
