The UAE Domestic Minimum Top-Up Tax (DMTT) came into effect for financial years starting on or after January 1, 2025 — meaning calendar-year filers saw their first DMTT-impacted FY close on December 31, 2025, with returns due through 2026.
Who it applies to
Multinational Enterprise (MNE) groups with consolidated global revenue of €750 million or more in at least two of the four preceding fiscal years. This mirrors the OECD Pillar Two / GloBE rules.
Who is out
- Standalone UAE companies (no foreign parent or subs)
- MNE groups under €750M global revenue
- Pure government entities, non-profits, pension funds
- Investment funds that are Ultimate Parent Entities
The rate
15% effective tax rate (ETR) on adjusted profits attributable to UAE entities. This sits alongside the 9% federal Corporate Tax regime — DMTT is a top-up when the 9% CT (on in-scope MNE branches) falls below the 15% minimum.
QFZPs (Qualifying Free Zone Persons)
Free Zone entities that qualify for 0% CT still face 15% DMTT if they're in an in-scope MNE group. The 0% Free Zone benefit is effectively neutralised for large MNEs — one of the biggest structural changes in UAE tax policy since CT launch in 2023.
Who this matters for right now
- Large US/EU/Asian MNEs with UAE subs or branches
- GCC family-office structures where the UAE entity is part of a €750M+ group
- Shipping, trading, and financial services groups in DIFC/ADGM with consolidated global revenue above threshold
Filing practicalities
First DMTT filing is due 15 months after year-end for the first reporting year, 18 months thereafter. Most calendar-year FY25 filers will file through Q1-Q2 2026.
What standalone UAE businesses should know
If your business is UAE-domestic, no DMTT impact. The 9% Corporate Tax (on taxable income above AED 375k) continues to apply unchanged. VAT at 5% unchanged. No personal income tax.
Our UAE Corporate Tax and VAT calculators remain tuned to standalone-UAE scenarios. Enterprise MNE DMTT modelling requires group-level Pillar Two calculations beyond a public calculator's scope.