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Signature Series · Corporate Tax · Tax

UAE Pillar Two — Domestic Minimum Top-up Tax

A practical 8-day programme on the UAE Domestic Minimum Top-up Tax, Pillar Two income, covered taxes, ETR calculations, safe harbours and compliance.

  • 📈 Advanced Professional Programme
  • 🖥 In-person / Online
  • ⏱ 8 Days · 24 Learning Hours
  • In-person Dates Location FeeUSD 1,225
    Virtual Dates LocationOnline FeeUSD 950
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ICMA International

Professional Accounting Body / Institute · Karachi, Pakistan

Established in 1951, the Institute of Cost and Management Accountants of Pakistan, internationally recognised as ICMA International, is a leading professional accounting body dedicated…

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Azeem Hussain Siddiqui, FCMA

Azeem Hussain Siddiqui, FCMA

President, ICMA International

About this Course

Total Programme Duration: 8 Days · 24 Learning Hours

Module 1 · Day 2 · 3 Hours

Scope and Constituent Entities

Determining Which Groups and UAE Entities Are In Scope

  • EUR 750 million consolidated revenue threshold
  • Application of the two-out-of-four fiscal year test
  • Identification of Constituent Entities
  • Excluded Entities and their treatment
  • Permanent Establishments and UAE branches
  • Investment Entities and Joint Ventures
  • Minority-owned Constituent Entities
  • Practical group-scoping exercise
Module 2 · Day 3 · 3 Hours

Pillar Two Income or Loss

Calculating GloBE Income under Article 3

  • Starting point for Pillar Two Income or Loss
  • Consolidated financial-statement line items versus standalone IFRS accounts
  • Application of Article 3.1.2
  • Treatment of excluded dividends and equity gains or losses
  • Policy-disallowed and other required adjustments
  • Pension-related adjustments
  • Transfer-pricing alignment under the GloBE Rules
  • Allocation of income to Permanent Establishments
  • Worked Pillar Two Income computation
Module 2 · Day 4 · 3 Hours

Adjusted Covered Taxes

Determining the Tax Amount Used in the ETR Calculation

  • Identifying Covered Taxes
  • Current tax expense, additions and reductions
  • Deferred-tax adjustments under Article 4
  • Recasting deferred-tax balances at 9%
  • Deferred Tax Liability Recapture Rule
  • Pillar Two Loss Election
  • Allocation of Covered Taxes between Constituent Entities
  • Blocking rule for taxes of a Main Entity outside the UAE
  • Worked Adjusted Covered Taxes calculation
Module 3 · Day 5 · 3 Hours

ETR and Substance-Based Income Exclusion

From Jurisdictional Blending to Excess Profit

  • Jurisdictional blending of UAE Constituent Entities
  • Calculating the UAE Effective Tax Rate
  • Interaction between the 9% Corporate Tax rate and the 15% minimum rate
  • The Qualifying Free Zone Person paradox
  • Substance-Based Income Exclusion
  • Eligible payroll costs and qualifying employees
  • Eligible tangible assets
  • Transitional exclusion percentages and annual reductions
  • Calculating Excess Profit after the substance carve-out
Module 3 · Day 6 · 3 Hours

Top-up Tax Computation

Calculating and Allocating the UAE Domestic Minimum Top-up Tax

  • Determining the Top-up Tax percentage
  • Calculating jurisdictional Top-up Tax
  • Treatment of Additional Current Top-up Tax
  • Allocation of Top-up Tax across UAE Constituent Entities
  • De Minimis Exclusion requirements
  • Interaction between losses, Covered Taxes and the ETR
  • Complete worked example using AED figures
  • Building the calculation in an Excel-based model
Module 4 · Day 7 · 3 Hours

Safe Harbours, Elections and Transition Rules

Reducing Compliance and Managing Strategic Elections

  • Transitional CbCR Safe Harbour
  • De Minimis Test
  • Simplified ETR Test
  • Routine Profits Test
  • Safe-harbour disqualification triggers
  • “Once out, always out” principle
  • Simplified Calculations Safe Harbour
  • Non-material Constituent Entities
  • Five-year and annual elections
  • Election assessment, documentation and strategy
  • Article 9 opening deferred-tax balances
  • Asset transfers after 30 November 2021
  • Initial phase of international activity relief
Module 4 · Day 8 · 3 Hours

Restructurings, Compliance and Advisory Practice

Managing QDMTT from Assessment to Filing

  • Corporate restructurings under the GloBE Rules
  • Acquisitions and disposals during a Fiscal Year
  • Changes in group composition
  • EmaraTax registration requirements
  • Preparing and submitting the Top-up Tax Return
  • Standard 15-month filing deadline
  • Transitional 18-month filing deadline
  • Record-keeping and supporting documentation
  • Penalty relief and the reasonable-measures standard
  • Managing queries and engagement with the FTA
  • Client scoping and QDMTT impact assessments
  • Developing a client-ready Excel computation model

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