Ministerial Decision No. 96 of 2026 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

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, 

- Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises,

- Ministerial Decision No. 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, 

Has decided:

Article 1 - Commentary and Agreed Administrative Guidance 

Commentary and Agreed Administrative Guidance stipulated in the Annexure attached to this Decision shall be adopted for the purposes of Cabinet Decision No. 142 of 2024 referred to above. 

Article 2 - Application of the Decision to Fiscal Years 

This Decision shall apply to Fiscal Years starting on or after 01 January ...