The UAE Ministry of Finance has issued Decision No. 88 of 2025, approving the list of international commentaries and agreed administrative guidance prepared by the Organisation for Economic Co-operation and Development (OECD) for the purposes of applying the Top-up Tax to multinational enterprises.
The document officially confirms that, for the purposes of applying Cabinet Decision No. 142 of 2024 in the UAE, the following are used:
- The consolidated commentary to the GloBE Model Rules published by the OECD,
- As well as the administrative guidance approved and published under the OECD’s Inclusive Framework on Base Erosion and Profit Shifting (BEPS) as of 1 January 2025.
GloBE is an internationally agreed mechanism that ensures multinational enterprises with annual consolidated revenues exceeding EUR 750 million pay at least 15% tax on the profits earned in each jurisdiction where they operate.
It should be recalled that Cabinet Decision No. 142 of 2024 applies only to multinational enterprises with consolidated revenue of at least EUR 750 million per year and establishes a minimum effecti...