UAE Domestic Minimum Top-up Tax

Cabinet Decision No. 142 of 2024 imposes a Domestic Minimum Top-up Tax on UAE Constituent Entities of MNE Groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding Fiscal Years (Annexure Article 1.1.1), for Fiscal Years beginning on or after 1 January 2025 (Article 2 of the Decision). This workbook runs the Decision's own arithmetic for the UAE as one jurisdiction: the revenue test with the Article 1.1.2 short-year adjustment, Pillar Two Income or Loss per entity from Financial Accounting Net Income and the Article 3.2.1 adjustments, Adjusted Covered Taxes (Article 4.1), the Effective Tax Rate and Top-up Tax Percentage against the 15% Minimum Rate (Articles 5.1 and 5.2), the Substance-based Income Exclusion at the Article 9.2 transition rates (9.6% payroll and 7.6% tangible assets for 2025, stepping down to 5.8% and 5.4% for 2032), Excess Profit and the Top-up Tax (Article 5.2.3), the Article 4.1.5 additional tax when covered taxes turn negative, and the split between entities under Article 5.2.4.

Two exclusions can set the result to zero and both are tested: the de minimis exclusion (Article 5.5: Average Pillar Two Revenue below EUR 10 million and Average Pillar Two Income below EUR 1 million over the current and two preceding years) and the Transitional CbCR Safe Harbour (Article 8.2.1: the EUR 10 million and EUR 1 million test, the Simplified ETR against the 16% or 17% Transition Rate, or the routine profits test) for Fiscal Years in the Transition Period. The return and payment dates follow Articles 8.1.2 and 11.1: 15 months after the Fiscal Year end, 18 in the first Transition Year, paid in UAE Dirhams.

• Every threshold, rate and date sits on a Rules sheet with its article; the Sources sheet links the Decision as published by the Federal Tax Authority and the Ministry of Finance Top-up Tax page.
• Ten cases (in and out of scope, 2025 and 2026 rates, a short year, de minimis, safe harbour, Article 4.1.5, SBIE waived, ETR above 15%, a 2033 year at the standard 5% rates) were recalculated with a formula engine and matched to an independent Python replica before listing.
• Up to eight UAE Constituent Entities, Investment Entities excluded as Articles 2.3 and 5.1.3 require. Live formulas, no macros, no locked cells; opens in Excel and Google Sheets. A working tool, not tax advice: the entity classification, Covered Taxes and the elections are facts you confirm, and the Guide says where.