Since financial years starting on 1 January 2025, UAE entities of multinational groups with global revenue of at least EUR 750 million in two of the previous four years pay a Domestic Minimum Top-up Tax. It tops their UAE effective tax rate up to 15%. Returns and payment are due 15 months after the year end.
Which groups are in scope?
Multinational groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years, under Cabinet Decision No. 142 of 2024 (PwC Middle East).
How is the top-up calculated?
The UAE effective tax rate of in-scope entities is compared with 15%, and the top-up percentage is the gap. A group with a UAE effective rate of 9% pays roughly a further 6% of its adjusted UAE profit, after the substance-based carve-outs (PwC). The standard 9% rate still applies to everyone else (Cabinet Decision No. 116 of 2022).
When are returns due?
The top-up tax return and payment are due 15 months after the end of the period, or 18 months for the first transition year. A Pillar Two information return follows the same 15-month timing (PwC).
What should in-scope groups do now?
Map UAE entities, collect the data the GloBE rules need, model the effective rate, and check whether free zone 0% income pulls the rate below 15%.
Is your group in scope? Four questions
- Does the group prepare consolidated financial statements?
- Did consolidated revenue reach EUR 750 million in at least two of the last four years?
- Does it have UAE entities or permanent establishments?
- Is the UAE effective tax rate below 15%?
Yes to all four means a top-up is likely (PwC).
Why free zone income matters here
A group with UAE profits taxed at 0% as qualifying free zone income can have a UAE effective rate well below 15%, even though each entity is fully compliant with the 9% regime (Cabinet Decision No. 116 of 2022). Model the rate entity by entity before the first return.
Our view
Start with data, not law. Groups that can produce entity-level profit, tax and payroll numbers quickly will find the calculation manageable; groups that cannot will spend most of the first year building that dataset.
Frequently asked questions
Does the DMTT affect small UAE businesses?
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No. Only groups above EUR 750 million revenue.
Does it replace the 9% corporate tax?
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No. It is an extra top-up for in-scope groups.
Are free zone companies covered?
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Yes, if they belong to an in-scope group.
Does the DMTT apply to a UAE-only group?
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The rules target multinational groups above the revenue threshold.
Sources
- UAE implements Pillar Two: Domestic Minimum Top-up Tax (Cabinet Decision No. 142 of 2024) — PwC Middle East. Checked 17 October 2026.
- Cabinet Decision No. 116 of 2022 on the annual Taxable Income subject to Corporate Tax (AED 375,000) — UAE Ministry of Finance. Checked 16 October 2026.