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May 15, 2026

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