GloBE Country Guide: The UAE

Summary

Status	Enacted Law
Law	On June 22, 2026, the UAE issued Ministerial Decision No. 96 of 2026. It formally adopts the latest OECD interpretive materials for the UAE’s QDMTT regime including the 2026 Consolidated Commentary, the 2026 Administrative Guidance/Central Record, and the January 2025 GloBE Information Return. It applies to fiscal years beginning on or after 1 January 2025, repeals Ministerial Decision No. 88 of 2025, and took effect from its date of issuance. Ministerial Decision No. (88) of 2025 issued on April 16, 2025 Cabinet Decision 142 of 2024 issued on February 8, 2025 Federal Decree Law No. 60 of 2023 issued on November 24, 2023
Effective Date	Financial years beginning on or after January 1, 2025
IIR	No
UTPR	No
QDMTT	Yes (2025)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour and the Simplified calculations for Non-Material Constituent Entities Safe Harbour. The relevant aspects of the OCED side-by-side tax package have also been implemented.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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