The UAE Ministry of Finance has issued Ministerial Decision No. (88) of 2025, officially adopting all guidance published by the Organisation for Economic Co-operation and Development (OECD) on Global Anti-Base Erosion (GloBE) Rules under Pillar Two.
This move comes on the heels of Cabinet Decision No. (142) of 2024, which introduced a Top-up Tax targeting Multinational Enterprises (MNEs). Together, the decisions mark a significant step in aligning the UAE’s tax framework with international standards.
By incorporating all OECD Administrative Guidance and commentary up to January 2025, the UAE reinforces its commitment to the OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS), of which it is an active member. The Ministry emphasised that this alignment will ensure consistency in the UAE’s Domestic Minimum Top-up Tax (DMTT) regime while streamlining compliance for affected MNEs.
The adoption of the OECD’s comprehensive guidance aims to support transparency, reduce tax avoidance risks, and enhance the UAE’s global competitiveness through the application of clear, consistent, and internationally recognised tax rules.
News Source: Emirates News Agency
