Tax & compliance

Pillar 2 top-up tax support in the UAE

Understand how the UAE domestic minimum top-up tax may affect your multinational group. DSB supports scope assessment, finance-data preparation and coordination with your group tax team.

Who this service is for

UAE finance and tax teams within multinational groups assessing Pillar Two obligations, exclusions and the information needed for group reporting.

Which groups should assess their position?

The UAE rules apply to relevant constituent entities of multinational groups whose consolidated annual revenue reaches EUR 750 million in at least two of the preceding four financial years. The regime applies to financial years beginning on or after 1 January 2025. Entity exclusions, elections and reliefs require a separate assessment.

Reference: UAE Ministry of Finance — Top-up Tax

Start with the group, then the UAE entities

Map the ownership structure, ultimate parent, constituent entities, financial reporting periods and responsibilities. Agree the data needed by the group tax team before starting calculations.

Coordinate accounting and tax information

Review the availability of financial statements, consolidation data, current and deferred tax information and relevant elections. Identify gaps, responsible owners and review steps.

What the engagement can deliver

Scope assessment

Document the initial group and entity scope, assumptions and questions requiring further analysis.

Data readiness review

Map source records and reporting requirements; identify missing information and responsible teams.

Group reporting coordination

Support the agreed information exchange between UAE finance teams, group tax teams and specialist advisers.

Compliance work plan

Set out agreed responsibilities, review points and next steps based on the applicable rules.

Final deliverables, exclusions, fees and responsibilities are confirmed in the written engagement.

How the work progresses

  1. Confirm the group structure and reporting period.
  2. Assess scope and identify matters requiring specialist review.
  3. Reconcile available finance and tax records with the information requested.
  4. Agree the work plan and documented handover with the group team.

What to prepare

  • Group ownership and entity structure
  • Consolidated financial statements and revenue history
  • UAE entity financial statements and tax records
  • Existing group Pillar Two instructions and reporting templates

Start with a business summary. Agree a secure channel before sharing confidential records.

Questions clients ask

Does Pillar Two apply to every UAE company?

No. Scope depends on the multinational group, revenue tests and entity-specific rules. Ordinary UAE Corporate Tax and top-up tax require distinct assessments.

Can DSB work with our existing group advisers?

Yes. We can agree a defined UAE data and coordination role with your finance team and group advisers.

What should we prepare for the first discussion?

Start with your group structure, consolidated revenue history, reporting periods and the instructions received from the group tax team.

Related services

Official references

Checked 30 October 2026. Confirm current requirements and applicability to your entity.

Technical basis

Cabinet Decision 142 of 2024, Article 2 and annexure Articles 1.1 and 1.5.

Source documents checked against DSB’s UAE Laws reference library on 30 October 2026. Applicability depends on the entity, transaction and reporting period.

Official source

Let’s put your next step
in clear focus.

Tell us about your business. We’ll help define the scope.

Discuss your requirements