The UAE Ministry of Finance has published a list of “frequently asked questions” (FAQs) regarding its Pillar Two domestic minimum top-up tax (DMTT).
According to the Ministry of Finance’s FAQs:
- The UAE DMTT is expected to achieve “qualified” status under the OECD peer review process, as it closely aligns with the global anti-base erosion (GloBE) model rules. However, the UAE has decided not to implement the income inclusion rule (IIR) charging mechanism at this stage, consistent with its decision not to include a controlled foreign company (CFC) regime within its corporate tax law. The UAE will continue to monitor the DMTT's implementation and effectiveness to assess the potential introduction of an IIR in the future.
- While there are some variations between the UAE DMTT rules and the OECD GloBE rules, these differences do not compromise the UAE DMTT's ability to benefit from the QDMTT safe harbour.
- The UAE DMTT includes a mechanism to adopt future OECD Administrative Guidance and Commentary.
- The financial accounting net income/loss of a company may be computed using an Acceptable Financial Accounting Standard or an Authorized Financial Accounting Standard, adjusted to prevent material competitive distortions. This ensures compliance with the Local Financial Accounting Standard Rule for the QDMTT safe harbour.
- UAE qualifying free zone persons (QFZPs) are not precluded from complying with the UAE DMTT rules if the thresholds are met.
Read a March 2025 report prepared by the KPMG member firm in the UAE