23/06/2026
UAE Pillar Two & DMTT Compliance: Is Your Business Ready? π¦πͺ
The UAE has entered a new phase of international tax compliance with the introduction of the Domestic Minimum Top-up Tax (DMTT) under the OECDβs Pillar Two framework. Multinational groups operating in the UAE must now assess their global tax position, reporting obligations, and eligibility for available reliefs.
Key highlights include:
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Applies to Multinational Enterprise (MNE) Groups with consolidated revenues exceeding β¬750 million in at least two of the previous four financial years.
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Effective from 1 January 2025 for qualifying entities.
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Mandatory Registration through EmaraTax for affected groups.
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First Top-up Tax filing deadlines expected by 30 June 2027 for many calendar-year entities.
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Access to Transitional Safe Harbour provisions and Substance-Based Income Exclusion (SBIE) may help reduce compliance burdens where eligibility criteria are met.
Businesses should also review the three key Safe Harbour tests:
π De Minimis Test
π Simplified Effective Tax Rate (ETR) Test
π Routine Profits Test
Early impact assessments, data readiness reviews, and compliance planning are critical to avoid future reporting challenges and ensure alignment with global minimum tax requirements.
APMH assists multinational groups with Pillar Two readiness assessments, DMTT compliance reviews, tax impact analysis, reporting frameworks, and regulatory guidance across the GCC region.
π§ [email protected]
π +91 8291278383
π www.apmhconsulting.com