A Comprehensive Guide and Checklist for Pillar Two in UAE for Multinational Enterprises

A Comprehensive Guide and Checklist for Pillar Two in UAE for Multinational Enterprises

Transfer pricing is a complex issue that businesses face while expanding their operations in multiple countries. Among the new amendments laid down by The Organization for Economic Cooperation and Development (OECD) under its new amendments towards its Base Erosion and profit Shifting (BEPS) project, includes the updated Pillar Two regulations, which is undoubtedly one of the most significant Transfer Pricing developments impacting multinational enterprises (MNEs) worldwide. In UAE, the introduction of Pillar Two regulations carries significant implications for tax management operations for MNEs. As such, it’s important to understand the core principles of Pillar Two and the checklist to ensure compliance in the UAE market. 

  1. Understanding the Pillar Two concept 

Pillar Two, the key elements being the Global Minimum Tax (GloBE) is a newly introduced framework by the OECD to eliminate base erosion and profit shifting and ensure that MNEs do not exploit global corporate tax disparities. The significant feature of Pillar Two is the introduction of a minimum tax rate on the MNEs’ global profits, which can be applied if the profits of these entities in low tax jurisdictions fall below a predefined threshold as compared with the areas having higher tax rates. In this way, Pillar Two aims to maintain a level playing field and minimize the likelihood of MNEs shifting their profits to tax havens or low-tax jurisdictions. 

  • Key Points on Pillar Two regulations for MNEs in UAE 

  UAE has never been a foreign country for the MNEs, and many of them have seen strong growth in the region over the years. However, with the implementation of Pillar Two and the adoption of the new Global Minimum Tax, MNEs having their headquarters in the UAE will need to pay closer attention to their operations in the UAE. The regulations for Pillar Two in general are complex, and MNEs also need to prepare themselves for changes in the future. Some of the essential aspects that MNEs should consider under Pillar Two regulations include: 

  • Understanding the methodology for defining the low-tax jurisdictions.
  • Preparing the conditions for the application of the figure for the effective minimum tax rate, which should be in line with the regulations. 
  • Determining the tax credit eligibility under Pillar Two to avoid double taxation in different jurisdictions. 
  • Carrying out an impact analysis and reviewing the tax management structure to align it with the new regulations. 

  • Checklist for Compliance 

The following checklist provides guidelines that MNEs operating in the UAE must consider to ensure compliance with Pillar Two regulations: 

  • Carry out an impact analysis to determine the MNEs profit margins 
  • Identify weightage of the low-tax affiliates, and allocate profits to high-tax jurisdictions appropriately 
  • Prepare to ensure the minimum tax rate does not apply to entities located in high tax areas 
  • Set up an effective tax framework 
  • Design the financial structures to ensure the nearly settled transactions align with Pillar Two regulations. 

A Comprehensive Guide and Checklist for Pillar Two in UAE for Multinational Enterprises

  • Future developments 

The introduction of Pillar Two in UAE will undoubtedly create room for experiences and changes for MNEs. It is crucial to note that organizations, particularly MNEs in the UAE, should keep a close watch on the changes of tax laws and regulations. Enterprises must always stay vigilant and monitor their tax management operations, and risk mitigation plans to ensure maximum compliance and harmonization with evolving tax laws, especially in the case of Pillar Two compliance. 


Pillar Two is designed to reduce the likelihood of profit-shifting and tax evasion by MNEs. MNEs operating in the UAE will need to be made aware of any future developments in the area. Therefore, it is the responsibility of MNEs to have a comprehensive understanding of the new Pillar Two framework and its implications. Doing so will ensure their continued compliance with tax regulations and positively impact their operations in the UAE. Businesses must review their tax management framework, conduct impact analyses, and design suitable fiscal structures to align with the new regulations. Compliance must be of utmost priority for MNEs to ensure they avoid penalties, double taxation, and strengthen their reputation in the UAE. With the right knowledge, preparation, and adherence to the regulations, organizations should expect no negative consequences from the adoption of Pillar Two. 

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