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UNITED ARAB EMIRATES: THE MINISTRY OF FINANCE RELEASES PUBLIC CONSULTATION ON
THE INTRODUCTION OF GLOBAL MINIMUM TAX FRAMEWORK

Baker McKenzie
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United Arab Emirates March 19 2024

In brief

This consultation will be relevant for all businesses operating in the UAE that
are part of a multinational group with global revenue exceeding EUR 750 million.
The release of this consultation continues to reaffirm the UAE's commitment to
implementing the Pillar 2 framework (essentially the adoption of a minimum 15%
corporate tax rate) although the timeframe for such implementation remains
unclear. All businesses impacted by this potential introduction should consider
the consultation and provide their views accordingly. With support from our
Global Pillar 2 Steering Committee, Baker McKenzie will be considering the
consultation in detail and will be happy to support taxpayers with their
submissions taking into account the OECD Model Rules, as well as what we have
seen other jurisdictions implement across the globe.

The consultation released by the UAE MoF focuses on obtaining views from
taxpayers on how the global minimum tax policy could be designed. The
consultation itself provides limited views by the UAE MoF as to how such a
policy is currently intended to be implemented, however the consultation
document itself does note the following key points:

 * The UAE MoF is considering the implementation of the Income Inclusion Rule
   ("IIR"), the Undertaxed Profits Rule ("UTPR") and/or a Domestic Minimum
   Top-Up Tax ("DMTT") (that could subsequently become a Qualifying DMTT (or
   "QDMTT") post peer review) with a focus on interaction with the UAE CT regime
   and minimizing compliance costs;
 * A proposal not to apply the IIR to smaller UAE headquartered groups (with
   global revenue below EUR 750 million in line with the OECD Model Rules) to
   manage compliance costs;
 * Where introduced, a QDMTT would not extend to groups that are below the EUR
   750 million threshold, and groups that are domestic (i.e., UAE) only;
 * The Safe Harbour regulations would not be adopted should a QDMTT be
   introduced;
 * The financial accounting standards that would be used would be IFRS;
 * The UAE MoF is considering the introduction of substance-based incentives,
   and the questions raised in the consultation focus on understanding how
   taxpayers benefit from other substance-based incentives around the globe.

 



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"Attorney Advertising" requiring notice in some jurisdictions. Prior results do
not guarantee similar outcomes. For more information, please
visit: www.bakermckenzie.com/en/client-resource-disclaimer.



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seamless advice, underpinned by deep practice and sector expertise, as well as
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Visit InsightPlus to access insights and analysis on the latest news, legal
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Visit Bakermckenzie.com to find out more about our services and how we can
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