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UAE Following OECD Commentary and Agreed Administrative Guidance for Qualified Domestic Minimum Top-up Tax

17 April 2025

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Approved Changes

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United Arab Emirates

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. As previously reported, Cabinet Decision No. 142 of 2024 introduced a qualified domestic minimum top-up tax (QDMTT), referred to as the UAE DMTT, which applies from 1 January 2025. Ministerial Decision No. 88 provides that the following OECD Commentary and Agreed Administrative Guidance shall be adopted for the purposes of Cabinet Decision No. 142 of 2024: OECD (2024), Tax Challenges Arising...