Latest news with #UAEDomesticMinimumTop-upTax
Zawya
11-04-2025
- Business
- Zawya
UAE Cabinet issues decision on non-residence's nexus linked to corporate tax law
UAE – The UAE Ministry of Finance has announced a new decision that specifies the cases in which a non-resident juridical investor in a Qualifying Investment Fund (QIF) or Real Estate Investment Trust (REIT) is considered to have a nexus and is therefore subject to taxation. The Cabinet issued Decision No. 35 of 2025 on the Determination of a Non-Resident Person's Nexus in the State for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses which replaces the provisions of Cabinet Decision No. 56 of 2023, according to an official statement. This follows the issuance of Cabinet Decision No. 34 of 2025 on Qualifying Investment Funds and Qualifying Limited Partnerships for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses. Under the new decision, a nexus for a non-resident juridical investor in a QIF that breaches the real estate threshold will arise either on the date of the dividend distribution if the QIF distributes 80% or more of its income within nine months from its financial year-end, or the date the ownership interest is acquired, in the case where the QIF fails to distribute at least 80% of its income within nine months from its financial year-end. A nexus will also be created for a non-resident juridical investor in a QIF that fails to meet the diversity of ownership conditions in the tax period in which the failure occurs. Furthermore, a nexus for a non-resident juridical investor in a REIT will arise either on the date of the dividend distribution if the REIT distributes 80% or more of its income within nine months from its financial year-end, or the date the ownership interest is acquired, in the case where the REIT fails to distribute at least 80% of its income within nine months from its financial year-end. Other than the above cases, non-resident juridical investors investing exclusively in a QIF and/or REIT will not be considered to have a taxable presence in the UAE. This decision reduces foreign investors' compliance burdens and reflects the UAE government's commitment to providing an attractive investment environment for such investors. Earlier in 2025, the UAE finance ministry announced a decree covering the introduction of the top-up tax for multinational enterprises, providing further details on the UAE Domestic Minimum Top-up Tax (UAE DMTT). Source: Mubasher
Zawya
10-02-2025
- Business
- Zawya
UAE issues cabinet decision on top-up tax for multinationals
The UAE Ministry of Finance has announced the issuance of Cabinet Decision No. 142 of 2024 on the introduction of the Top-up Tax for Multinational Enterprises, providing further details on the UAE Domestic Minimum Top-up Tax (UAE DMTT). This follows the announcement made by the Ministry on December 9, 2024, said an Emirates News Agency (Wam) report. The UAE DMTT is closely aligned with the GloBE Model Rules issued by the Organisation for Economic Co-operation and Development (OECD). The UAE DMTT will apply to Entities that are members of Multinational Enterprises (MNEs) operating in the UAE with annual global revenues of €750 million or more in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two out of the four financial years immediately preceding the financial year in which the UAE DMTT applies. The UAE DMTT provides relief through a Substance-based Income Exclusion, a carve out which reduces net Pillar Two income subject to the UAE DMTT to determine the Excess Profit for the purposes of computing the UAE DMTT, by an amount calculated based on payroll and the carrying value of tangible assets. Aligned with the GloBE Model Rules, the UAE DMTT also allows for an exclusion where an Entity meets the relevant de minimis exclusion criteria, under which the UAE DMTT for an Entity will be considered zero, provided that certain criteria are met. To bolster the UAE's competitiveness as a leading investment hub, the UAE DMTT has been structured to exclude Investment Entities, as defined under these rules, the report said. As part of a transitional measure and to create a tax environment conducive to economic growth, no UAE DMTT will be levied during the initial phase of an MNE Group's international activity, provided that none of the of the ownership interests of the Entities located in the UAE are held by a parent entity subject to a Qualified Income Inclusion Rule in another Jurisdiction. Copyright 2024 Al Hilal Publishing and Marketing Group Provided by SyndiGate Media Inc. (
Trade Arabia
09-02-2025
- Business
- Trade Arabia
UAE issues cabinet decision on top-up tax for multinationals
The UAE Ministry of Finance has announced the issuance of Cabinet Decision No. 142 of 2024 on the introduction of the Top-up Tax for Multinational Enterprises, providing further details on the UAE Domestic Minimum Top-up Tax (UAE DMTT). This follows the announcement made by the Ministry on December 9, 2024, said an Emirates News Agency (Wam) report. The UAE DMTT is closely aligned with the GloBE Model Rules issued by the Organisation for Economic Co-operation and Development (OECD). The UAE DMTT will apply to Entities that are members of Multinational Enterprises (MNEs) operating in the UAE with annual global revenues of €750 million or more in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two out of the four financial years immediately preceding the financial year in which the UAE DMTT applies. The UAE DMTT provides relief through a Substance-based Income Exclusion, a carve out which reduces net Pillar Two income subject to the UAE DMTT to determine the Excess Profit for the purposes of computing the UAE DMTT, by an amount calculated based on payroll and the carrying value of tangible assets. Aligned with the GloBE Model Rules, the UAE DMTT also allows for an exclusion where an Entity meets the relevant de minimis exclusion criteria, under which the UAE DMTT for an Entity will be considered zero, provided that certain criteria are met. To bolster the UAE's competitiveness as a leading investment hub, the UAE DMTT has been structured to exclude Investment Entities, as defined under these rules, the report said. As part of a transitional measure and to create a tax environment conducive to economic growth, no UAE DMTT will be levied during the initial phase of an MNE Group's international activity, provided that none of the of the ownership interests of the Entities located in the UAE are held by a parent entity subject to a Qualified Income Inclusion Rule in another Jurisdiction.
Emirates 24/7
07-02-2025
- Business
- Emirates 24/7
Ministry of Finance Announces Issuance of a Cabinet Decision on the Introduction of Top-up Tax for Multinational Enterprises
The Ministry of Finance has announced the issuance of Cabinet Decision No. 142 of 2024 on the introduction of the Top-up Tax for Multinational Enterprises, providing further details on the UAE Domestic Minimum Top-up Tax (UAE DMTT). This follows the announcement made by the Ministry on December 9, 2024. The UAE DMTT is closely aligned with the GloBE Model Rules issued by the Organisation for Economic Co-operation and Development (OECD). The UAE DMTT will apply to Entities that are members of Multinational Enterprises (MNEs) operating in the UAE with annual global revenues of €750 million or more in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two out of the four financial years immediately preceding the financial year in which the UAE DMTT applies. The UAE DMTT provides relief through a Substance-based Income Exclusion, a carve out which reduces net Pillar Two income subject to the UAE DMTT to determine the Excess Profit for the purposes of computing the UAE DMTT, by an amount calculated based on payroll and the carrying value of tangible assets. Aligned with the GloBE Model Rules, the UAE DMTT also allows for an exclusion where an Entity meets the relevant de minimis exclusion criteria, under which the UAE DMTT for an Entity will be considered zero, provided that certain criteria are met. To bolster the UAE's competitiveness as a leading investment hub, the UAE DMTT has been structured to exclude Investment Entities, as defined under these rules. As part of a transitional measure and to create a tax environment conducive to economic growth, no UAE DMTT will be levied during the initial phase of an MNE Group's international activity, provided that none of the of the ownership interests of the Entities located in the UAE are held by a parent entity subject to a Qualified Income Inclusion Rule in another Jurisdiction. The UAE DMTT should be interpreted in line with the Commentary and Administrative Guidance issued by the OECD, available via this link. Cabinet Decision No. 142 of 2024 is available on the UAE Legislation's website: Follow Emirates 24|7 on Google News.
