GTL Summary:

This Article amends Federal Decree-Law No. 47 of 2022 by incorporating two new definitions, 'Top-up Tax' and 'Multinational Enterprise', into Article 1. The 'Top-up Tax' is defined in alignment with OECD Pillar Two rules. Furthermore, the Article introduces a new Clause (3) to Article 3 of the original Decree-Law. This addition mandates the Cabinet, upon the Minister's suggestion, to issue decisions regulating the imposition of Top-up Tax on Multinational Enterprises, ensuring the total effective tax rate reaches 15 per cent.

Document Type: Tax Law Article
Law: DMTT (FDL No 60 of 2023)
Article Number: 1
Country: 🇦🇪 UAE
Order: 1
Last updated at: 2026-02-23 12:13:39 UTC

Article 1

[GTL Notes: Amendment to Article 1 and Article 3 of FDL 47 of 2022]

1. Two new definitions shall be added to the definitions under Article 1 of the Federal Decree-Law No. 47 of 2022 referred to above:

Top-up Tax

:

The top-up tax imposed on Multinational Enterprises in accordance with this Decree-Law and the rules and controls to be determined by the Cabinet under Article 3 of this Decree-Law for the purposes of the pillar two rules issued by the Organization for Economic Cooperation and Development.

Multinational Enterprise

:

An entity and/or one or more of its member entities located in the State or in a foreign jurisdiction, as specified in a decision to be issued by the Cabinet at the suggestion of the Minister.

2. A new Clause numbered (3) shall be added to Article 3 of the Federal Decree-Law No. 47 of 2022 referred to above, its text is as follows:

Article (3 Clause 3)

Without prejudice to the provisions of Clauses (1) and (2) of this Article, the Cabinet at the suggestion of the Minister shall issue a decision regulating all cases, provisions, conditions, rules, controls, and procedures for imposing the Top-up Tax on Multinational Enterprises and the exemptions therefrom, so that the total percentage of the effective tax imposed on them is (15%) fifteen percent.

Fast-loading version for search engines - Click here for the interactive version