UAE Domestic Minimum Top-Up Tax Calculator
UAE introduced 15% DMTT in 2025 for multinational groups under OECD Pillar Two rules. Applies if global group revenue exceeds €750M in 2 of 4 prior years.
| Group global revenue threshold (€750M) | — |
| Status: in-scope or out | — |
| UAE entity net profit | — |
| Corporate Tax paid (9% standard CIT) | — |
| Effective Tax Rate (ETR) before DMTT | — |
| Minimum ETR target (15%) | — |
| Top-up rate (15% - ETR) | — |
| DMTT top-up tax | — |
The UAE Domestic Minimum Top-Up Tax (DMTT) is a 15% effective tax rate applied to multinational enterprise (MNE) groups whose global consolidated revenue exceeds €750 million. Implemented in 2025 to comply with the OECD Pillar Two GloBE rules, the DMTT ensures that large multinationals pay at least 15% effective tax in the UAE — alongside the standard 9% corporate tax for entities above AED 375K profit threshold.
Who Is In Scope of UAE DMTT
The UAE DMTT applies to constituent entities of MNE groups meeting two conditions: (1) the group's consolidated global revenue is at least €750 million in at least 2 of the 4 fiscal years immediately preceding the current year, AND (2) the entity is located in the UAE. Smaller standalone companies (revenue below threshold) continue to pay only the standard 9% UAE corporate tax. Most local businesses are not in scope.
How DMTT Calculation Works
The DMTT calculates a 'top-up tax' equal to the difference between 15% (minimum effective tax rate target) and the actual effective tax rate (ETR) on UAE profits. If the UAE entity has already paid 9% standard CIT, the DMTT adds an additional 6% to bring ETR to 15%. The calculation uses 'GloBE income' which has specific adjustments from financial accounting profit — including share-based compensation, pension differences, and substance-based income exclusion (a deduction for tangible asset and payroll costs).
Impact and Strategic Considerations
For UAE free zone entities that previously benefited from 0% tax rates, the DMTT effectively eliminates that advantage if they belong to an in-scope MNE group. UAE-based MNE groups should plan around: (1) substance-based income exclusion to reduce DMTT base, (2) compliance with new transfer pricing documentation, (3) GloBE Information Return filings, (4) coordination with parent jurisdiction's Income Inclusion Rule (IIR) to avoid double taxation. UAE Federal Tax Authority published detailed Cabinet Decision No. 116/2024 with implementation rules. Effective: fiscal years starting on or after January 1, 2025.
Last updated May 2026. Sources: UAE Ministry of Finance.