GTL Summary:

TThis decision formally adopts specific OECD publications as the official commentary and administrative guidance for Cabinet Decision No. 142 of 2024 concerning the Imposition of Top-Up Tax on Multinational Enterprises. The adopted documents include the OECD's Consolidated Commentary to the GloBE Model Rules, various Administrative Guidance documents on Pillar Two, and the GloBE Information Return. By adopting these materials, the decision ensures that the interpretation and application of the UAE's Top-Up Tax regime are aligned with the international framework developed under the OECD/G20 BEPS project, providing a consistent standard for compliance.

Document Type: MD - Ministerial Decision
Law: CIT (FDL No 47 of 2022, as amended)
Decision Number: 88
Year: 2025
Country: 🇦🇪 UAE
Official Name: Ministerial Decision No. 88 of 2025 - Issued 28 Mar 2025 (Effective from 1 Jan 2025)
Last updated at: 2025-11-04 11:19:40 UTC

This is not an Official Translation:

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

Ministerial Decision No. 88 of 2025

Issued 28 Mar 2025 - (Effective from 1 Jan 2025)

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 Hussaini

Minister 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

  1. 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.

  2. OECD 2024, Tax Challenges Arising from 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.

  3. OECD 2025, Tax Challenges Arising from 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.

  4. OECD 2025, Tax Challenges Arising from 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.

  5. OECD 2025, Tax Challenges Arising from 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.

  6. 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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