Adoption of OECD Commentary and Guidance Documents for UAE DMTT

On 28 March 2025, the UAE Ministry of Finance issued Ministerial Decision No. 88 of 2025 (the “Decision”) to formally adopt the following Commentary and Agreed Administrative Guidance for the purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises (MNEs). This aligns the UAE’s Domestic Minimum Top-up Tax (‘DMTT’) framework with the OECD’s Model Rules, effective for financial years starting on or after 1 January 2025.

Andersen takeaway and Way forward

The expected adoption of these OECD guidance documents signals a significant step towards global alignment, providing taxpayers with a consistent interpretive framework. It also raises the bar for compliance, requiring robust documentation, consistent transfer pricing, and early-stage provisioning for top-up taxes.

We recommend that businesses:

• Review their models in light of the updated OECD guidance.
• Reassess the impact of intra-group transactions and financial structures.
• Prepare for GloBE Information Return filings and data readiness.
• Engage with advisors to identify any transitional reliefs or safe harbors that may be applicable.