This decision formally adopts specific OECD publications as the official commentary and administrative guidance for Cabinet Decision No. 142 of 2024 concerning the Imposition of Top-Up Tax on Multinational Enterprises. The adopted documents include the OECD's Consolidated Commentary to the GloBE Model Rules, various Administrative Guidance documents on Pillar Two, and the GloBE Information Return. By adopting these materials, the decision ensures that the interpretation and application of the UAE's Top-Up Tax regime are aligned with the international framework developed under the OECD/G20 BEPS project, providing a consistent standard for compliance.
The 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
Ministerial Decision No. 88 of 2025
Issued 28 Mar 2025 - (Effective from 1 Jan 2025)
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