{"id":6166,"date":"2026-01-28T14:06:14","date_gmt":"2026-01-28T14:06:14","guid":{"rendered":"https:\/\/well-tax.com\/?p=6166"},"modified":"2026-01-29T13:31:38","modified_gmt":"2026-01-29T13:31:38","slug":"6-%d0%b2%d0%b0%d0%b6%d0%bd%d1%8b%d1%85-%d1%84%d0%b0%d0%ba%d1%82%d0%be%d0%b2-%d0%be-%d0%bd%d0%b0%d0%bb%d0%be%d0%b3%d0%b5-%d0%bd%d0%b0-%d0%bc%d0%b8%d0%bd%d0%b8%d0%bc%d0%b0%d0%bb%d1%8c%d0%bd%d1%8b%d0%b9","status":"publish","type":"post","link":"https:\/\/well-tax.com\/ru\/6-essential-facts-on-the-uae-domestic-minimum-top-up-tax\/","title":{"rendered":"6 \u043e\u0441\u043d\u043e\u0432\u043d\u044b\u0445 \u0444\u0430\u043a\u0442\u043e\u0432 \u043e \u043c\u0438\u043d\u0438\u043c\u0430\u043b\u044c\u043d\u043e\u043c \u043d\u0430\u043b\u043e\u0433\u0435 \u043d\u0430 \u043f\u0440\u0438\u0431\u044b\u043b\u044c \u0432 \u041e\u0410\u042d"},"content":{"rendered":"\n
\"UAE<\/figure>\n\n\n\n

The United Arab Emirates has taken a significant step towards global tax compliance with the issuance of Cabinet Decision No. 142 of 2024, introducing the UAE Domestic Minimum Top-up Tax (DMTT) for multinational enterprises effective from 1 January 2025. This measure aligns the UAE with the OECD\u2019s Pillar II Model Rules, designed to promote equitable tax practices and ensure that multinational corporations contribute fairly to the jurisdictions in which they operate. By implementing the DMTT, the UAE reinforces its commitment to harmonising domestic tax policies with international standards and fostering transparency in the global tax landscape.<\/p>\n\n\n\n

Scope and Applicability<\/h2>\n\n\n\n

The UAE Domestic Minimum Top-up Tax applies to Constituent Entities that are part of a Multinational Enterprise (MNE) Group with annual consolidated revenue of EUR 750 million or more, as reported in the Ultimate Parent Entity\u2019s financial statements for at least two of the four financial years preceding the financial year under review. An MNE Group is defined as any group that includes at least one entity or permanent establishment outside the jurisdiction of the Ultimate Parent Entity, covering organisations with cross-border operations.<\/p>\n\n\n\n

Entities Covered<\/h3>\n\n\n\n

The UAE Domestic Minimum Top-up Tax rules apply to:<\/p>\n\n\n\n

\u2022             Constituent Entities based in the UAE<\/p>\n\n\n\n

\u2022             Joint Ventures and JV Subsidiaries of a Domestic JV Group<\/p>\n\n\n\n

\u2022             Reverse Hybrid Entities established under UAE law<\/p>\n\n\n\n

Excluded Entities<\/h3>\n\n\n\n

Certain entities are exempt from UAE Domestic Minimum Top-up Tax, including:<\/p>\n\n\n\n

\u2022             Governmental Entities<\/p>\n\n\n\n

\u2022             International Organisations<\/p>\n\n\n\n

\u2022             Non-profit Organisations<\/p>\n\n\n\n

\u2022             Pension Funds<\/p>\n\n\n\n

\u2022             Investment Funds that are Ultimate Parent Entities<\/p>\n\n\n\n

\u2022             Real Estate Investment Vehicles that are Ultimate Parent Entities<\/p>\n\n\n\n

\"Are<\/figure>\n\n\n\n

Calculation of the UAE Domestic Minimum Top-up Tax<\/h2>\n\n\n\n

The UAE Domestic Minimum Top-up Tax (DMTT) calculation follows the GloBE Model Rules and involves several steps. First, businesses compute the total adjusted income and adjusted taxes for all non-excluded UAE entities. These figures are used to determine the Effective Tax Rate (ETR) by dividing aggregated taxes by aggregated income. If the ETR is below 15%, the difference becomes the top-up tax percentage.<\/p>\n\n\n\n

Next, substance-based income exclusions are applied, which allow deductions based on eligible payroll costs and tangible assets, starting at 9.6% and 7.6% respectively, and gradually reducing to 5% by 2033. After applying these exclusions, the top-up tax is calculated by multiplying the remaining income by the top-up tax percentage. Finally, any additional tax liabilities are assessed, and adjustments are made to arrive at the total DMTT obligation.<\/p>\n\n\n\n

Safe Harbours and Transitional Reliefs<\/h2>\n\n\n\n

The UAE Domestic Minimum Top-up Tax framework introduces specific safe harbours and relief measures designed to ease compliance and reduce administrative burdens for qualifying entities:<\/p>\n\n\n\n

De Minimis Safe Harbour<\/h3>\n\n\n\n

The UAE Top-up Tax is nil if:<\/p>\n\n\n\n

\u2022             The aggregate average revenue in the UAE is below EUR 10m; and<\/p>\n\n\n\n

\u2022             The average DMTT Income or Loss does not exceed EUR 1m for the current and two prior financial years.<\/p>\n\n\n\n

Transitional Country-by-Country Reporting Safe Harbour<\/h3>\n\n\n\n

The UAE Top-up Tax due may be considered nil if any of the simplified tests are met, De-Minimis Test, ETR Test or Routine Profit Test. This is only applicable for fiscal years beginning on or before1 January 2027 and excluding fiscal years ending after 1 July 2028. A qualified CbCR is a requirement to access this safe harbour.<\/p>\n\n\n\n

Initial phase of international activity exclusion<\/h3>\n\n\n\n

The UAE Top-up Tax due may be considered nil if:<\/p>\n\n\n\n

\u2022             The MNE Group operates in no more than six jurisdictions and holds Tangible Assets below EUR 50m outside its reference jurisdiction; and<\/p>\n\n\n\n

\u2022             No interest in the UAE CEs \/ JVs is owned by a parent entity in the group which applies the Income Inclusion Rule.<\/p>\n\n\n\n

This exclusion is available for a maximum of five years from the date the MNE Group becomes subject to the Pillar Two rules.<\/p>\n\n\n\n

Simplified Computation Safe Harbour<\/h3>\n\n\n\n

The UAE Top-up Tax shall be deemed to be zero for a Financial Year provided that the MNE Group meets one of the following tests with respect to its operations in the UAE:<\/p>\n\n\n\n

\u2022             Routine Profits Test;<\/p>\n\n\n\n

\u2022             De Minimis Test; or<\/p>\n\n\n\n

\u2022             Effective Tax Rate Test<\/p>\n\n\n\t\t

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