Pillar Two · Dubai, UAE
UAE Domestic Minimum Top-up Tax (DMTT) 2026: Pillar Two & the 15% Rate
A 15% minimum tax — but only for the giants
From financial years starting on or after 1 January 2025, the UAE applies a Domestic Minimum Top-up Tax (DMTT) that lifts the effective tax rate of large multinational groups to a 15% floor. It is the UAE's implementation of the OECD's Pillar Two. The critical point for most readers: it only touches groups with consolidated revenue of at least EUR 750 million. If that is not you, your rate stays at 0% (as a QFZP) or 9% — nothing changes.
The DMTT exists for a strategic reason. Under Pillar Two, if a big group is taxed below 15% in the UAE, another country could collect the shortfall. By charging its own top-up, the UAE keeps that revenue at home instead of surrendering it abroad.
Who Is Actually In Scope
How the Top-up Is Calculated
The top-up simply closes the gap to 15%. You compute a jurisdictional effective tax rate (ETR) — covered taxes divided by GloBE income for all UAE entities combined. A substance-based income exclusion first strips out a routine return on payroll and tangible assets, so only "excess" profit is exposed. If the UAE ETR is below 15%, the top-up percentage applies to that excess.
Why a 9% Rate Can Still Trigger a Top-up
Here is the subtle part for in-scope groups: the headline 9% corporate tax rate does not guarantee a 15% ETR. Incentives, exempt income, or 0% qualifying free zone income can pull the effective rate below 15% — and that shortfall is exactly what the DMTT collects. The real work is not the arithmetic; it is assembling GloBE-standard data across the whole group in time to file.
What In-Scope Groups Should Do Now
- Confirm scope by testing consolidated revenue against EUR 750 million.
- Register the UAE constituent entities for the top-up tax.
- Build the GloBE data process across every entity and jurisdiction.
- Model the UAE ETR to see whether a top-up arises — before filing.
- Prepare the GloBE information return and meet the DMTT deadlines.
Is Your Group In Scope of the DMTT?
Exiloz tests your group against the EUR 750M threshold, models your UAE effective tax rate, and prepares the GloBE return. See our corporate tax service or talk to a consultant today.
Frequently Asked Questions
Does the UAE DMTT apply to my small business?
Almost certainly not. It only applies to MNE groups with EUR 750 million or more in consolidated revenue. SMEs and standalone companies keep their 0% or 9% rate.
When did the UAE DMTT take effect?
For financial years beginning on or after 1 January 2025.
How is the DMTT top-up calculated?
It is the gap between 15% and your jurisdictional ETR (covered taxes ÷ GloBE income), applied to excess profit after a substance-based carve-out.
Why did the UAE introduce a DMTT?
So any top-up on UAE profits is collected in the UAE rather than by another country under the IIR or UTPR.
Explore the Domestic Minimum Top-up Tax Cluster
Each page below goes deeper on one part of this topic.
Step 01 · ScopeWho Is In Scope of DMTTThe EUR 750M group revenue test.Explore →Step 02 · GloBEThe Pillar Two GloBE RulesHow the global minimum tax works.Explore →Step 03 · ETREffective Tax Rate & Top-upHow the 15% shortfall is calculated.Explore →Step 04 · ComplianceDMTT Registration & FilingWhat in-scope groups must file.Explore →
