EAU squeezes the corporate tax framework with key updates on audited finances and global minimum tax rules
As part of its continuous efforts to improve transparency and align with international fiscal standards, the Eau Ministry of Finance has announced two significant developments that directly affect corporate compliance and structuring multinational groups in the country. This is what companies need to know.
Ministerial Decision No. 84 or 2025 – Mandatory Auditory Financial Statements for Fiscal Groups
In April 2025, the Ministry issued Ministerial Decision No. 84 or 2025, amending the previous decision No. 82 or 2023 with respect to the audited financial statements under the EAU Corporate Tax Law (((((((((Federal Decree No. 47 or 2022). This marks a fundamental change in report obligations, especially for fiscal groups.
Key changes introduced:
- Added financial statements now mandatory for all fiscal groups
- Regardless of annual income, all fiscal groups are now obliged to prepare and submit added financial statements of special audited purpose for corporate taxes purposes. This standardize the reports and eliminates the previous exemption that applies to groups with revenues below the 50 million AED.
- Woster of independent audits within the groups
- Entities that are part of a fiscal group are no longer obliged to maintain separate audited financial statements, simplifying the compliance process and reducing the duplication of audit efforts.
- Requirements without changes for non -group entities
- Entities that are not part of a fiscal group must continue to prepare audited finances if their annual income exceeds the AED 50 million or if they claim the status of the person of qualified free zone (QFZP).
- Clarification for non -residents
- It is required that non -resident legal persons consider only the income of origin of the EAU (through the permanent establishment or Nexus) to determine if they comply with the audit threshold of 50 million AED.
- PENDING TLC Guide for QFZPS
- Additional requirements for QFZP will be issued soon that participate in distribution activities of designated areas, probably affecting many companies operating in logistics and shopping centers.
Adoption of the OECD orientation on the global minimum tax (Marco del Pilar Dos)
In a parallel movement with global implications, the EAU have announced the adoption of the OECD orientation and comments on the rules of global anti-base erosion (Globe) under Pilar Dos. This decision reinforces the EAU’s commitment to international tax standards and is expected to remode the landscape for large multinational companies (MNES).
What this means:
- 15% minimum minimum recharge tax (DMTT)
- As of January 1, 2025, a 15% DMTT will apply to EMNs with global consolidated income of € 750 million or more in two of the last four financial years. This ensures that EMN paid a minimum level of taxes in the EAU, regardless of local incentives.
- Alignment with the OECD pillar two objectives
- The measure is part of the EAU commitment to the minimum global fiscal framework, with the aim of reducing the harmful fiscal competence and the change of profits.
- Future incentives that are considered
- The ministry is also evaluating economic incentives that are two pillars, such as:
- A Fiscal Research and Development Credit (30–50%)
- A high -value labor credit based on qualified personnel based on the EAU
- These are subject to a legislative approach and would serve to set up the competitiveness of the EAU and remain complying with international standards.
What companies should do now
These ads have compliance challenges and strategic opportunities:
- Fiscal groups must review their reporting processes and guarantee preparation for consolidated audited finances.
- Free zone entities claiming the QFZP State must verify audit obligations and track the next orientation.
- The MNE operating in the EAU must evaluate their exposure under 15% of DMTT and the structuring of the evaluation entity and the local substance accordingly.
The direction of the EAU is clear: aligning locally with the global fiscal integrity initiatives while preserving its attraction for foreign investment through intelligent and intelligent regulation.
This article is written by Marco Marazzi, Legal Advisor of Solutions Business in Bizzmosis Group
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