UAE DMTT scope checker
Is your group inside the EUR 750 million revenue test? Four years of revenue answer it.
Sources
Quoted from Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises, as published in the Official Gazette.
“This Decision shall apply to Constituent Entities that are members of an MNE Group that has annual revenue of EUR 750 million or more in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two of the four Fiscal Years immediately preceding the tested Fiscal Year. Further rules are set out in Article 6.1 which modify the application of the consolidated revenue threshold in certain cases.”
“If one or more of the Fiscal Years of the MNE Group taken into account for purposes of Article 1.1.1 is of a period other than 12 months, for each of those Fiscal Years the EUR 750 million threshold is adjusted proportionally to correspond with the length of the relevant Fiscal Year.”
“An MNE Group means any Group that includes at least one Entity or Permanent Establishment that is not located in the Jurisdiction in which the Ultimate Parent Entity of the MNE Group is located.”
“For purposes of determining whether a threshold in this Decision is met, the relevant amounts expressed in a currency other than the EUR have to be converted into EUR using the average of the daily reference rates of the month of December prior to the commencement of the relevant Fiscal Year, as quoted by: (a) the European Central Bank; (b) where the European Central Bank does not provide a foreign exchange reference rate for the local currency of a Jurisdiction, the average foreign exchange rate will be determined by that quoted by the Central Bank of the UAE; or (c) if neither the European Central Bank nor the Central Bank of the UAE quotes a daily rate of exchange in respect of the two currencies, the foreign exchange rate shall be determined by another source acceptable to the Federal Tax Authority.”
“Any Entity that is subject to Top-up Tax pursuant to this Decision and a Domestic Designated Filing Entity, shall register with the Federal Tax Authority in the form and manner and within the timeline prescribed by it.”
“This Decision shall apply to the Fiscal Years beginning on or after 1 January 2025.”
Registration deadline
Article 13.1 leaves the timeline to the FTA, and the text of the FTA decision that sets it is not in our verified sources. No date is shown here. Confirm your registration deadline with the FTA.
The checker's logic is covered by known-answer tests, including the FTA Guide TTGREG1 Examples 13, 14 and 15. Read more on the Pillar Two and DMTT service page.