As part of its ongoing efforts to enhance financial transparency and align with international standards, the United Arab Emirates has recently introduced significant regulatory updates in the field of taxation. These updates concern, on one hand, the requirements for preparing audited financial statements under the Corporate Tax regime, and on the other hand, the introduction of the so-called “Top-up Tax” for multinational groups. Below is a comprehensive overview of the key developments.
New Requirements for Audited Financial Statements under the Corporate Tax Regime
With the goal of strengthening financial reporting standards and ensuring transparent tax practices, the UAE Ministry of Finance has issued an updated Ministerial Decision No. 84 of 2025 on Audited Financial Statements for clarifying the requirements for audited financial statements, in accordance with Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses.
Key updates include:
- Obligation for Tax Groups: All tax groups registered in the UAE are now required to prepare special purpose aggregated audited financial statements that reflect the financial position of the group for Corporate Tax purposes.
- A Taxable Person that is not a Tax Group and that derives Revenue exceeding AED 50,000,000 (fifty million United Arab Emirates dirhams) during the relevant Tax Period.
The updated decision also clarify that for Qualifying Free Zone Persons engaged in the distribution of goods or materials within or from a Designated Zone shall comply with preparation of audited financial statements.
Introduction of the Top-up Tax in Line with OECD Framework
In parallel, the UAE Ministry of Finance announced the issuance of Ministerial Decision No. 88 of 2025, which fully adopts the guidance issued by the Organisation for Economic Co-operation and Development (OECD) regarding the Global Anti-Base Erosion (GloBE) Rules – Pillar Two, as part of the broader BEPS (Base Erosion and Profit Shifting) initiative.
This measure follows Cabinet Decision No. 142 of 2024, which introduced the Top-up Tax applicable to multinational enterprises operating in the UAE.
Key points of the new regulation:
- Full Adoption of OECD Guidance: The UAE adopts all relevant OECD administrative guidance, commentary, and updates issued up to January 2025, reaffirming its commitment to international tax standards.
- Alignment with the GloBE Framework: The introduction of the Domestic Minimum Top-up Tax (DMTT) aligns the UAE’s domestic tax rules with the OECD GloBE Model Rules, ensuring consistency and clarity.
- Reduced Compliance Burden: The adopted approach is designed to ease the compliance process for in-scope multinational enterprises by providing a streamlined and predictable regulatory framework.
The recent tax measures adopted by the UAE represent a significant step towards greater transparency, regulatory solidity, and international alignment. By setting clear requirements for audited financial statements and adopting the Top-up Tax under OECD standards, the UAE strengthens its position as a globally competitive and trusted jurisdiction.
Kelmer Group will continue to monitor these regulatory developments and support its clients in adapting to the new requirements, offering strategic and operational guidance to ensure full tax compliance in the United Arab Emirates.