UAE Advances BEPS Commitments with New OECD-Aligned Tax Rule

UAE, 17 April, 2025 : The UAE Ministry of Finance has issued Ministerial Decision No. (88) of 2025, officially adopting all OECD guidance on Global Anti-Base Erosion (GloBE) Rules, known as Pillar Two. This move follows Cabinet Decision No. (142) of 2024, which introduced a Top-up Tax on Multinational Enterprises.

The decision aligns the UAE’s Domestic Minimum Top-up Tax (DMTT) framework with the OECD’s GloBE Model Rules and incorporates all Administrative Guidance and related commentary issued up to January 2025.

This step reaffirms the UAE’s commitment to international tax standards under the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), aiming to provide clarity and reduce the compliance burden for in-scope multinational groups.