01
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.
02
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.
03
Document text
This is an independent editorial overview, not the official text or a complete translation. Application requires checking the Arabic original, current version and transitional provisions.
An independent four-language editorial overview is published; the full instrument is not yet reproduced on-site.. This is an independent editorial overview, not the official text or a complete translation. Application requires checking the Arabic original, current version and transitional provisions.
04
Publication status
Source and translation status
The official Arabic text controls; the English version on the official portal is for reference. This page contains an independent SGC editorial overview.
Legal review
Number, date, scope, principal exclusions, effective status and official URL were checked; the overview is not advice on a specific matter. · September 13, 2026
Republication status
Only instrument metadata, an official deep link and an original editorial explanation are used. The FTA/MoF PDF, layout and compilation are not copied; full-text reproduction requires a separate source and rights review.
Change history
- 31 December 2024 — instrument issued; applies to fiscal years from 1 January 2025.
- Reviewed 13 September 2026
06
Official primary source
Cabinet Decision No. 142 of 2024
Only instrument metadata, an official deep link and an original editorial explanation are used. The FTA/MoF PDF, layout and compilation are not copied; full-text reproduction requires a separate source and rights review.
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