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Document overview
The UAE's core Pillar Two instrument defining in-scope multinational groups, the effective-tax-rate calculation and top-up to a 15% minimum.
- Minimum effective tax rate: 15%.
- Group threshold: EUR 750 million.
- Specific rules for UAE Investment Entities and excluded entities.
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Scope and exclusions
Applies to
MNE groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding years; applies to fiscal years beginning on or after 1 January 2025.
Limitations and exclusions
Excluded entities include government and international organisations, NPOs, pension funds and certain UPE investment funds, real-estate vehicles and qualifying owned entities.
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Official primary source
Cabinet Decision No. 142 of 2024
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