Domestic Minimum Top-up Tax (DMTT) effective
Large multinationals (€750m+ consolidated revenue) subject to 15% effective rate on UAE profits via DMTT.
What changed and what to do
What changed
From 1 January 2025, the UAE applies a Domestic Minimum Top-up Tax aligned with OECD Pillar Two. Multinational groups with consolidated revenue of €750m+ in at least two of the last four years pay a top-up to bring their effective UAE rate to 15%. Standard companies continue under the regular 9% Corporate Tax regime.
Who it affects
- UAE entities within multinational groups with €750m+ consolidated revenue
- Free zone companies inside such groups (qualifying status doesn't override DMTT)
- Standard SMEs and owner-managed companies are unaffected
What to do
In-scope groups must register for DMTT and file GloBE returns. Standard SMEs stay on the 9% Corporate Tax regime with no additional filing.
Small Business Relief: revenue under AED 3m
Taxable persons with revenue under AED 3m can elect to be treated as having zero taxable income, available through the period ending 31 December 2026.
What changed and what to do
What changed
Cabinet Decision 73 of 2023 introduced Small Business Relief. Companies with revenue under AED 3,000,000 in the current and all previous tax periods (back to 1 June 2023) can elect to be treated as having no taxable income, eliminating Corporation Tax liability. The relief expires at the end of the tax period ending on or after 31 December 2026 unless extended.
Who it affects
- UAE-resident companies with revenue under AED 3m/year
- Small mainland and free zone (non-qualifying) businesses
What to do
Elect for the relief on your Corporate Tax return. You must still register for CT, file returns and maintain records: the relief just reduces the taxable income to zero.
Free zone Qualifying Income clarifications
Further FTA guidance issued on what counts as Qualifying Income for free zone persons benefiting from the 0% rate.
What changed and what to do
What changed
The FTA issued additional clarifications on Qualifying Free Zone Person status: the 0% rate applies only to Qualifying Income (transactions with other free zone persons, certain qualifying activities, foreign customers). Excluded activities, transactions with mainland UAE and any non-qualifying income beyond the de minimis threshold (lower of AED 5m or 5% of total revenue) are taxed at 9%.
Who it affects
- Free zone companies seeking the 0% Corporate Tax rate
- DMCC, IFZA, JAFZA, DAFZA, ADGM and other free zone entities
What to do
Map your revenue streams to Qualifying vs non-Qualifying. Ensure substance and adequate operations requirements are met. Review the de minimis test annually.
Corporate Tax registration deadlines now penalty-driven
Failure to register for Corporate Tax by the FTA-specified deadline triggers an AED 10,000 administrative penalty.
What changed and what to do
What changed
FTA Decision 3 of 2024 set staggered Corporate Tax registration deadlines by month of licence issue. Companies that miss their deadline face an AED 10,000 administrative penalty. All taxable persons must register, including those electing Small Business Relief or qualifying for the 0% free zone rate.
Who it affects
- Every UAE mainland and free zone company
- Branches of foreign companies operating in the UAE
What to do
Check your licence issue date and confirm registration status on the EmaraTax portal. If you've missed your window, register immediately to limit further escalation.
E-invoicing rollout for B2B and B2G
Mandatory e-invoicing framework for B2B and B2G transactions being phased in from mid-2026.
What changed and what to do
What changed
The UAE Ministry of Finance announced an e-invoicing framework targeting Q3 2026 rollout for B2B and B2G transactions, with Peppol-style structured invoices. Phased thresholds and obligated parties to be confirmed.
Who it affects
- All VAT-registered businesses (anticipated)
- Companies invoicing other UAE businesses and government entities
What to do
Confirm your invoicing system can produce Peppol-compliant XML. Monitor FTA announcements through 2026 for the final timeline and thresholds.