Public Consultation

15 March 2024 – On 15 March 2024, the United Arab Emirates (UAE) Ministry of Finance (MoF) released the Global Minimum Tax Public Consultation. The aim of the consultation is to collect stakeholders' perspectives on the potential policy design options for implementing the GloBE rules in the UAE. 

To provide you with an overview, below we have highlighted some relevant aspects mentioned in the Consultation Questionnaire:  

  • The Income Inclusion Rule (IIR) will not apply to smaller UAE headquartered groups.
  • The MoF is evaluating the implementation of the IIR, Undertaxed Profit Rule (UTPR) and the Qualified Domestic Minimum Top-up Tax (QDMTT).
  • For the introduction of the QDMTT, the MoF has considered some “Optional variations” that deviate from the GloBE rules, as well as alternatives for the allocation of the liability among the UAE Constituent Entities of the group, among other aspects.
  • It also includes comments for the implementation of the QDMTT Safe Harbour.
  • In relation to compliance obligations, the MoF is proposing two alternatives: (i) top-up tax liabilities due in the UAE are paid annually and in line with UAE corporate tax payment deadlines or (ii) follow the timelines set by the GloBE Rules.
  • The MoF is considering implementing substance-based incentives. 

The deadline to provide comments is 10 April 2024.


Our tax experts listed below would be happy to discuss the above matters in more detail, or support you through a further discussion on your Tax requirements.

UAE Pillar 2 contacts

Alex Law 

Stephen Brunner

Jan Roderick Van Abbe

Pieter Schoorel

Robert Bird


Regional Pillar 2 contacts

Giuseppe Campolo 

Osama Abbasi

Peter Bourke


Did you find this useful?