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
Minister of State for Financial Affairs:
- Having reviewed the Constitution,
- Federal Law No. (1) of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
- Federal Decree-Law No. (47) of 2022 on the Taxation of Corporations and Businesses, and its amendments,
- Cabinet Decision No. (142) of 2024 on the Imposition of Top-Up Tax On Multinational Enterprises,
Has decided:
Article (1) Commentary and Agreed Administrative Guidance
The Commentary and Agreed Administrative Guidance stipulated in the list attached to this Decision shall be adopted for the purposes of Cabinet Decision No. (142) of 2024 referred to above.
Article (2) Publication and Application of the Decision
This Decision shall be published and be effective from 1 January 2025.
Mohamed bin Hadi Al HussainiMinister of State for Financial Affairs
Issued by us: On: 28 / Ramadan / 1446
Corresponding to: 28 / 03 / 2025
The 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
- 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.
- OECD (2024), Tax Challenges Arising f rom 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.
- OECD (2025), Tax Challenges Arising f rom 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.
- OECD (2025), Tax Challenges Arising f rom 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.
- OECD (2025), Tax Challenges Arising f rom 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.
- OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (January 2025), OECD/G20 Inclusive Framework on BEPS, OECD, Paris.
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Important Notice
The above extract has been provided for reference only and is based on information available in the public domain at the time of publication, which is subject to change. This does not constitute any form of advice or recommendation and therefore cannot be relied on to cover specific situations. We highly recommend that you consult with a qualified tax advisor in the UAE for personalized guidance based on your specific business circumstances. We accept no duty of care or liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication. Please refer to the following resources for the official and up-to-date information on the UAE Corporate Tax legal framework:- UAE Ministry of Finance: https://mof.gov.ae/tax-legislation/; and
- UAE Federal Tax Authority: https://tax.gov.ae/en/Legislation.aspx