UAE Transfer Pricing &
BEPS Pillar 2 Updates

Domestic Minimum Top-Up Tax (DMTT)

• UAE has introduced DMTT to align with OECD BEPS 2.0.
• Minimum ETR requirement of 15% for low-taxed entities.
• Effective for fiscal years starting on or after 1 January 2025.

Applicability Thresholds

• Applies to MNEs with revenue ≥ Euro 750 million.
• DMTT return must be filed within 15 months after fiscal year end.
• Registration with Federal Tax Authority (FTA) is mandatory.

Articles 34 - 36

The legal foundation in the UAE CT Law mandating the Arm’s Length Principle for Related Parties and Connected Persons.

FTA Decision No. 6

Specifies the thresholds and standards for maintaining Master Files and Local Files within the UAE jurisdiction.

Ministerial Decision 97

Provides clarity on the requirements for maintaining Transfer Pricing documentation and the submission of Disclosure Forms.