GTL Summary:

Cabinet Decision No. 142 of 2024 establishes the legal framework for the imposition of Top-up Tax on Multinational Enterprises within the United Arab Emirates. Issued on 31 December 2024, this Decision implements the Global Anti-Base Erosion rules in alignment with Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses. It specifies that the Top-up Tax applies to Fiscal Years starting on or after 1 January 2025. The Decision clarifies compliance rules and procedures detailed in its annexure, ensuring the UAE's alignment with international tax standards and Pillar Two requirements.

Document Type: CD - Cabinet Decision
Law: DMTT (FDL No 60 of 2023)
Decision Number: cabinet-decision-142-article-0-promulgation
Year: 2024
Country: 🇦🇪 UAE
Official Name: Cabinet Decision No. 142 of 2024 - Issued 31 Dec 2024 - (Effective from 1 Jan 2025)
Last updated at: 2026-03-23 15:38:05 UTC

This is not an Official Translation:

The Imposition of Top-up Tax on Multinational Enterprises

Cabinet Decision No. 142 of 2024

Issued 31 December of 2024 - (Effective from 1 January 2025)

The Cabinet has decided:

  • Having reviewed the Constitution;

  • Federal Law No. 1 of 1972 on the Competencies of the Ministries and Powers of the Ministers, and its amendments; and

  • Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments; and

  • Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments; and

  • Pursuant to what was presented by the Minister of Finance and upon the approval of the Cabinet.

Article 1 - The Imposition of Top-up Tax

The Top-up Tax shall be imposed on Multinational Enterprises in accordance with the cases, provisions, conditions, rules, controls and procedures contained in the annexure.

Article 2 - Application of the Decision to Financial Years

This Decision shall apply to the Fiscal Years beginning on or after 1 January 2025.

Article 3 - Publication and Application of the Decision

This Decision shall take effect on 1 January 2025 and shall be published in the Official Gazette.

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