9 July 2026 · GloBE
The Pillar Two GloBE Rules
Pillar Two is the OECD's global minimum tax framework. Its GloBE rules ensure large MNE groups pay an effective tax rate of at least 15% in every jurisdiction they operate. If a group is taxed below 15% somewhere, a top-up is collected — either by another country under the Income Inclusion Rule, or by the source country itself through a Domestic Minimum Top-up Tax. The UAE introduced a DMTT so that top-up on UAE profits is collected in the UAE rather than abroad.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
What Pillar Two does
The goal is a 15% floor on large-group profits everywhere they arise.
- Guarantees a 15% minimum effective tax rate per jurisdiction.
- Applies to MNE groups above EUR 750 million.
- Top-up is charged where the ETR falls below 15%.
- Collected via IIR, UTPR or a domestic top-up tax.
Keeping the top-up in the UAE
Without a DMTT, another country would collect tax on UAE profits.
- A DMTT lets the UAE collect its own top-up first.
- It aligns the UAE with the global framework.
- It protects UAE revenue from foreign IIR/UTPR charges.
- In-scope groups compute UAE ETR and pay any shortfall here.
Related guides
Frequently Asked Questions
For finance teams new to Pillar Two.
What is Pillar Two?
An OECD framework ensuring large multinational groups pay at least 15% effective tax in each jurisdiction, through the GloBE rules.
Why did the UAE introduce a DMTT?
So that any top-up owed on UAE profits is collected in the UAE, rather than by another country under the IIR or UTPR.
What are the IIR and UTPR?
Mechanisms under Pillar Two that let other countries collect top-up tax when profits are undertaxed; a DMTT takes priority over them domestically.
Can Exiloz help us understand our exposure?
Yes. We explain how the GloBE rules apply to your group and quantify the potential UAE top-up.
Make sense of Pillar Two
Exiloz translates the GloBE rules into what they actually mean for your UAE entities.