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May 15, 2026

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.

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.