Ministry of Finance Announces OECD Transitional Qualified Status for its Domestic Minium Top-up Tax (“DMTT”)

• This achievement demonstrates the UAE’s commitment to international tax standards and global alignment to the OECD and the Inclusive Framework on Base Erosion and Profit Shifting (IF on BEPS) rules and regulations
• The UAE’s DMTT qualifies to benefit from the OECD Pillar Two Safe Harbour
• Multinational enterprises (MNEs) operating in the UAE will be exempt from calculating top-up tax in other jurisdictions, thereby reducing administrative burdens and providing greater clarity, transparency, and certainty in tax compliance

Abu Dhabi, UAE - 25 August 2025:

The UAE Ministry of Finance (MoF) announced that the Organisation for Economic Co-operation and Development (OECD) has published the UAE’s Domestic Minimum Top-up Tax (DMTT) on its “Central Record of Legislation with Transitional Qualified Status” which can be found on their website:

https://www.oecd.org/en/topics/sub-issues/global-minimum-tax/central-record-of-legislation-with-transitional-qualified-status.html

The Ministry noted that our adherence to international tax standards, coupled with the OECD’s recognition, cements the UAE’s position as a world leading hub for international business and investment and drives its sustainable development agenda.

Under the qualified status, the UAE’s DMTT provides certainty to MNE groups that no foreign tax will be applied to UAE profits and acceptance of the UAE top up tax liability by other countries. Moreover, other jurisdictions will recognise the top-up tax obligations due in the UAE on these entities. Thus, minimising risk of complex and costly multilateral audit challenges and disputes.

The UAE’s DMTT has also qualified for the OECD Pillar 2 safe harbour, which reduces the administrative burden for both MNEs and the tax administration as top-up calculations are not required to be performed in other jurisdictions for UAE in scope entities.

The announcement of the qualifying status, therefore, provides clarity and certainty to MNEs doing business in the UAE.

All Cabinet Decisions and Ministerial Decisions relating to the DMTT are available on the Ministry of Finance's website: www.mof.gov.ae.