Ministerial Decision No. 88 of 2025, issued by the UAE Ministry of Finance, formally adopts the Commentary and Agreed Administrative Guidance under Cabinet Decision No. 142 of 2024 on the imposition of Top‑Up Tax on multinational enterprises.
The Decision aligns the UAE’s domestic framework with the OECD/G20 Inclusive Framework on BEPS, specifically the Global Anti-Base Erosion (GloBE) Model Rules under Pillar Two.
Effective from 1 January 2025, the Decision ensures consistent application and enforcement of the Top-Up Tax regime and provides legal certainty for multinational groups operating in or through the UAE.
Scope of Adopted Commentary and Guidance
The UAE has adopted a series of technical publications issued by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), OECD, Paris, for the purpose of implementing Cabinet Decision No. (142) of 2024.
The adopted publication-each issued as part of, Tax Challenges Arising from the Digitalisation of the Economy series, include:
- Consolidated Commentary to the GloBE Model Rules (2023) – OECD (2024)
- Administrative Guidance on the GloBE Model Rules (Pillar Two), June 2024 – OECD (2024)
- Administrative Guidance on the GloBE Model Rules – Central Record – OECD (2025)
- Administrative Guidance on Articles 8.1.4 and 8.1.5 of the GloBE Rules (January 2025) – OECD (2025)
- Administrative Guidance on Article 9.1 of the GloBE Rules – OECD (2025)
- GloBE Information Return (January 2025) – OECD (2025)
- Consolidated Commentary to the GloBE Model Rules (2023) – OECD (2024)
Conclusion
The promulgation of Ministerial Decision No. (88) of 2025 is a significant milestone in the UAE’s tax policy evolution. By adopting the Commentary and Agreed Administrative Guidance issued by the OECD/G20 Inclusive Framework, the UAE has affirmed its position as a cooperative and transparent jurisdiction that upholds the principles of global minimum taxation.
Partner with RVG
At RVG Chartered Accountants, we assist clients in assessing their exposure under the Top-Up Tax rules, interpreting the adopted OECD guidance, and implementing robust compliance frameworks tailored to their group structures. Our team offers end-to-end support—from impact assessments to the preparation of the GloBE Information Return, ensuring that your organisation remains fully aligned with both UAE requirements and international best practices.
For tailored advisory on Pillar Two implementation or assistance in meeting your multinational compliance obligations, please reach out to RVG Chartered Accountants.Book your free consultation today and get expert guidance from our experienced tax professionals.
