UAE: Retroactive implementation of OECD Pillar Two guidance

Commentary and administrative guidance apply retroactively as of January 1, 2025.

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April 30, 2025

The UAE Ministry of Finance on April 16, 2025, published Ministerial Decision No. 88 of 2025, incorporating the OECD / Inclusive Framework commentary and agreed administrative guidance into local legislation, including the:

  • April 2024 Consolidated Commentary
  • June 2024 Administrative Guidance
  • January 2025 Administrative Guidance on Articles 8.1.4/8.1.5 and 9.1 of the GloBE Model Rules
  • January 2025 (updated in March 2025) Administrative Guidance on the central record of legislation with transitional qualified status
  • Global Anti-Base Erosion (GloBE) information return release published in January 2025

The commentary and administrative guidance apply with a retroactive effect as of January 1, 2025.

The Ministerial Decision complements Cabinet Decision No. 142 of 2024, which introduced a domestic minimum top-up tax (DMTT) for fiscal years starting on or after January 1, 2025. The UAE is currently not implementing the income inclusion rule (IIR) or the undertaxed profits rule (UTPR). 

Read an April 2025 report prepared by KPMG’s EU Tax Centre

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