International Tax
Scoping, calculations and compliance for the UAE Domestic Minimum Top-up Tax on large multinational groups.
From financial years starting on or after 1 January 2025, the UAE applies a Domestic Minimum Top-up Tax so that large multinational groups pay at least 15% on their UAE profits. It applies to groups with consolidated revenue of EUR 750 million or more. We help in-scope groups and their UAE entities understand the impact and meet the new filing obligations.
Early clarity
Know whether top-up tax will apply before the first filing is due.
Reliable data
Identify the information your systems need to capture now, not at year end.
Use safe harbours
Transitional relief can simplify compliance where your group qualifies.
Aligned with group
UAE calculations are consistent with your group’s global Pillar Two reporting.
In-depth guide
01What Pillar Two means for the UAE
Pillar Two is the OECD’s global minimum tax framework. It aims to ensure large multinational groups pay at least 15% tax in each country where they operate. The UAE introduced its Domestic Minimum Top-up Tax so that any top-up due on UAE profits is collected in the UAE rather than by another country.
For in-scope groups, this changes the effect of the 9% Corporate Tax rate and of incentives such as the 0% Free Zone regime.
02The calculation in practice
The effective tax rate is calculated for all UAE entities of the group together, using GloBE income and covered taxes rather than ordinary accounting or tax figures. A substance-based exclusion for payroll and tangible assets can reduce the profit subject to top-up.
Much of the work lies in collecting data that finance systems were not built to capture. We help identify those gaps early and design a repeatable process.
03Registration and filing
In-scope groups must register for DMTT and file returns within deadlines set by the FTA, which are longer than for ordinary Corporate Tax. Transitional safe harbours may simplify the first years for groups that meet their tests.
We work alongside your group tax team and auditors so the UAE position is consistent with filings in other jurisdictions.
- 1
Scope
We confirm whether the group and its UAE entities fall within the rules.
- 2
Data review
We identify the financial and tax data needed and where gaps exist.
- 3
Model
We calculate the UAE effective tax rate and test safe harbours.
- 4
Comply
We support registration, returns and ongoing reporting.
UAE constituent entities of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding financial years.
International Tax
Other services
Ready for books you can rely on?
Book a free 30-minute consultation. We’ll review your current setup and show you exactly what we’d do.