Amendments to the UAE Corporate Tax Law

In this article we will discuss about the Amendments to the UAE Corporate Tax Law.

Introduction of Global Minimum Tax

In order to modify certain provisions of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, the UAE released Federal Decree Law No. (60) of 2023. This amendment has been done to streamline the implementation of domestic minimum taxes.

The key amendments are as follows:

(a) New Definitions

New terms have been incorporated in UAE Corporate Tax Law. “Top-up tax” will be defined as an additional tax levied on Multinational Enterprises (MNEs) to guarantee their adherence to an effective tax rate of 15%, aligning with the Pillar Two rules.

An “MNE” is defined as an entity and/or one or more of its member entities located in the State or in aforeign jurisdiction, as specified in a decision to be issued by the Cabinet at the suggestion of the Minister.

(b) Tax Rate

Over the period of time, a separate decision shall be issued detailing the mechanisms, terms, conditions, rules, and procedures for the application of the top-up tax on Multinational Enterprises (MNEs) in accordance with the Pillar Two rules.

(c) Commencement Date

The regulations concerning the top-up tax will come into force on the date of the Minister’s forthcoming decision, as published in the Official Gazette.

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