Cabinet Decision No. 142 of 2024 introduced the UAE Top-up Tax for Fiscal Years beginning on or after 1 January 2025. The regime forms part of the UAE’s implementation of the OECD Pillar Two framework. Generally, it applies to Constituent Entities of a Multinational Enterprise (MNE) Group with consolidated annual revenue of EUR 750 million or more in at least two of the four Fiscal Years preceding the tested Fiscal Year.
