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Starting Date: 15/03/2024
Closing Date: 10/04/2024
This will help inform the UAE Ministry of Finance on aspects such as, domestic implementation issues, such as interactions with the UAE's corporate tax system, ways to minimise compliance costs, while exploring the policy options for potential implementation of the Income Inclusion Rule, Undertaxed Profits Rule and a Domestic Minimum Top-up Tax.
Potential policy design options to respond to the implementation of the GloBE Rules in the UAE, in particular with the design of the UAE Domestic Minium Top-up Tax.
The consultation is with respect to the Global Minimum Tax or Global Anti-Base Erosion Model (Pillar Two) Rules approved by theG20 and the Organization for Economic Co-operation and Development Inclusive Framework on Base Erosion and Profit Shifting and how this should be best implemented in the UAE.
Summary of key conclusions drawn from the results:
Based on the responses, we noted that majority of respondents (which included, multinational enterprises and advisors) were in favour of the introduction of the GloBE Rules in the UAE with positive sentiments towards the introduction of a Domestic Minimum Top-up Tax (DMTT) and the Income Inclusion Rule. Respondents also highlighted the preference and importance of the rules to be aligned with the GloBE Model Rules as issued by the OECD and the need for the DMTT to achieve 'Qualified' and 'Safe Harbour' status
Identify the actions or steps planned based on the consultation results:
Based on feedback received, the UAE has already announced the introduction of a Domestic Minimum Top-up Tax, the draft legislation is finalised and released on December 2024. The implementation of an Income Inclusion Rule is still under assessment and may be considered to be introduced in the near future. The UAE legislation is closely aligned to the GloBE Model Rules.
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