UAE implements Pillar Two
The UAE has issued Cabinet Decision No (142) of 2024 that implements a Domestic Minimum Top-up Tax (“DMTT” or “DMTT Rules”) in the UAE. The Cabinet Decision follows on from the December 2024 announcement made by the Ministry of Finance. The DMTT will apply to Multinational Enterprises (“MNEs”) that are in scope of Pillar Two based on the OECD Global Anti-Base Erosion (“GloBE”) Model Rules, and will be imposed in cases where the MNE’s effective tax rate (“ETR”) in the UAE is below 15%.