Key implementation point
Free Zone regimes (0% rate) are directly in DMTT scope — significant for large MNEs with UAE Free Zone operations.
Implementation detail
- 01 UAE enacted QDMTT (DMTT) via Cabinet Decision 142 effective 1 January 2025.
- 02 IIR and UTPR not enacted — UAE collects top-up locally only.
- 03 UAE Corporate Tax introduced in June 2023 at 9% for profits above AED 375,000 — below 15% threshold.
- 04 Free Zone regimes (ADGM, DIFC, JAFZA, etc.) may qualify for 0% or 9% CT — DMTT critical for Free Zone entities meeting GloBE revenue threshold.
- 05 FTA (Federal Tax Authority) issued DMTT guidance.
- 06 Sovereign wealth fund entities and government-controlled entities may fall within excluded entity rules.
- 07 UAE is a significant holding jurisdiction for Middle East and Africa structures.
Enacted legislation
Cabinet Decision No. 142 of 2024
Official sources & further reading
Track United Arab Emirates rules against your live MNE
In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.
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