Tax · International Framework
Pillar Two — global minimum tax.
The OECD's framework establishing a 15% global minimum effective tax rate for large multinational enterprise (MNE) groups. Agreed by 140+ jurisdictions in 2021. UAE implementation effective January 2025.
Who's caught
MNE groups with consolidated annual revenue above EUR 750 million in at least two of the four preceding financial years. The threshold mirrors the OECD BEPS Country-by-Country Reporting threshold.
The three rules
- QDMTT (Qualified Domestic Minimum Top-up Tax) — local 15% rule. UAE's DMTT is a QDMTT.
- IIR (Income Inclusion Rule) — parent jurisdiction tops up undertaxed subsidiaries.
- UTPR (Undertaxed Profits Rule) — backstop where neither QDMTT nor IIR applies.