Ministerial Decision No. 96 of 2026 establishes the Commentary and Agreed Administrative Guidance for the purposes of Cabinet Decision No. 142 of 2024 regarding the imposition of Top-Up Tax on Multinational Enterprises (MNEs). The Decision formally adopts the OECD's consolidated commentary and guidance on the Global Anti-Base Erosion (GloBE) Model Rules, ensuring alignment with international minimum tax standards under the UAE Corporate Income Tax framework. Applicable to fiscal years commencing on or after 01 January 2025, this Decision explicitly repeals Ministerial Decision No. 88 of 2025. It provides critical interpretative guidance to facilitate compliance with the UAE's implementation of Pillar Two rules.