Navigate global tax reform with confidence

The UAE has officially implemented the OECD’s Pillar Two framework through Cabinet Decision No. (142) of 2024, introducing the Domestic Minimum Top-up Tax (DMTT) effective from 1 January 2025. This marks a significant shift in the UAE’s corporate tax landscape, ensuring that large multinational enterprises (MNEs) are subject to a minimum effective tax rate of 15%.

At Grant Thornton UAE, we specialize in helping businesses understand, comply with, and optimize their tax positions under the new Pillar Two regime.

Who is affected?

Pillar Two applies to MNE Groups with:

Annual consolidated revenues of €750 million or more in at least two of the four preceding fiscal years.

Operations in two or more jurisdictions, including UAE-based entities, joint ventures, and permanent establishments.

Why choose us?

Deep understanding of UAE tax law and regulatory expectations.

Alignment with OECD’s GloBE Model Rules and international best practices.

Customized strategies for your business structure and industry.

From initial readiness assessments to ongoing compliance and audit defense.

Our Pillar Two Services

We offer a comprehensive suite of services to support your compliance and strategic planning:

Scoping and impact assessment

  • Identify in-scope entities and assess exposure to DMTT.
  • Evaluate effective tax rates across jurisdictions.
     

Top-up tax calculation and reporting

  • Compute Pillar Two income, adjusted covered taxes, and top-up tax liabilities.
  • Prepare and file the Top-up Tax Return in accordance with UAE regulations.
     

Safe harbour and transitional relief advisory

  • Apply OECD’s transitional Country-by-Country Reporting (CbCR) safe harbours.
  • Leverage simplified calculation methods where applicable.

Technology and data readiness

  • Implement systems for data collection, tax provisioning, and reporting.
  • Align financial reporting standards with GloBE requirements.
     

Governance and strategic planning

  • Review global tax governance frameworks.
  • Advise on restructuring and intercompany arrangements to mitigate tax leakage.