Domestic Minimum Top-up Tax (DMTT) in the UAE

If your group’s consolidated revenue is EUR 750 million or more, your UAE entities must bear tax at an effective rate of at least 15%. The UAE’s domestic minimum top-up tax applies to fiscal years starting on or after 1 January 2025, and registration is open on EmaraTax. GSPU has built DMTT calculation models for GCC constituent entities and can take you from scoping to filing.

Is your group in scope?

Your UAE entities are constituent entities of a multinational group.
The group’s consolidated revenue was EUR 750 million or more in at least two of the four preceding fiscal years.
They are not excluded entities (certain government entities, pension funds and investment funds).

Why it matters in the UAE

The 9% corporate tax rate, the 0% free zone regime and Small Business Relief all leave UAE effective rates below 15%. For in-scope groups, the difference is now collected in the UAE.

Key obligations

Obligation	Position
Registration	On EmaraTax, separate from corporate tax registration [confirm the deadline for your group]
Returns	UAE top-up tax return plus the GloBE Information Return: 18 months after the first year end (30 June 2027 for calendar 2025), then 15 months (Cabinet Decision 142 of 2024)
Qualified status	The UAE DMTT has transitional qualified status, so paying in the UAE switches off top-up tax in the parent’s jurisdiction

How GSPU helps

Scoping memo: constituent entities, exclusions, safe harbours and first-year exposure
EmaraTax registration for each UAE constituent entity
GloBE computation: from IFRS accounts to covered taxes, effective tax rate and top-up
Free zone review: how the QFZP regime interacts with the top-up
Group coordination with your parent’s Pillar Two adviser and GSPU’s Oman and Bahrain offices