This 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.
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,
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
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