A Review of the UAE Consultation on the Introduction of the GloBE Rules

On March 15, 2024, the UAE launched a public consultation on the implementation of the GloBE rules in the UAE. The consultation is open until April 10, 2024.

The consultation seeks feedback on:

1. Policy options for the implementation of the Income Inclusion Rule (“IIR”), the Undertaxed Profits Rule (“UTPR”) and a Domestic Minimum Top-up Tax (“DMTT”).
2. Substance-based incentives

Pillar Two Implementation

As expected, the majority of the consultation focuses on design options for the DMTT (as domestic jurisdictions are given more flexibility over their QDMTT design).

Nevertheless, the consultation does confirm that: