Ministerial Decision No. 96 of 2026 refreshes the technical rulebook the UAE uses to apply its Top-Up Tax on large multinational groups. Issued on 22 June 2026, it formally adopts the latest OECD commentary and administrative guidance for the purposes of Cabinet Decision No. 142 of 2024, and repeals the earlier guidance decision, Ministerial Decision No. 88 of 2025.
Key takeaways
- Ministerial Decision No. 96 of 2026 adopts updated OECD commentary and Agreed Administrative Guidance for the UAE's Top-Up Tax under Cabinet Decision No. 142 of 2024.
- It applies to fiscal years starting on or after 1 January 2025 and takes effect from its issuance date, 22 June 2026, with no transitional period.
- It repeals and fully replaces Ministerial Decision No. 88 of 2025, the previous guidance decision.
- Three OECD publications now form the interpretive basis: the GloBE Consolidated Commentary (2026), the Administrative Guidance Central Record (2026), and the GloBE Information Return (January 2025).
- The 2026 Consolidated Commentary becomes the single reference for GloBE calculations and disclosures, folding several earlier standalone documents into one source with an integrated Annex B.
- Annex B — the Central Record of qualified jurisdictions — is updated on a rolling basis, so groups need a standing process to track changes.
What the UAE Top-Up Tax is, in one line
Pillar Two, or Top-Up Tax, is a global minimum tax designed to ensure that large multinational enterprises (MNEs) pay an effective tax rate of at least 15% in each jurisdiction where they operate. The UAE imposes it through Cabinet Decision No. 142 of 2024. Ministerial Decision No. 96 of 2026 does not change the tax itself — it updates the guidance used to calculate and report it.
What Ministerial Decision No. 96 of 2026 does
Ministerial Decision No. 96 of 2026 formally adopts the OECD Commentary and Agreed Administrative Guidance set out in its Annexure for the purposes of Cabinet Decision No. 142 of 2024 — short in form but consequential, and working article by article. The guidance reaches back to fiscal years starting on or after 1 January 2025, a retroactive posture groups must reflect in their compliance for those periods. Ministerial Decision No. 88 of 2025, the prior guidance decision, is repealed and fully replaced. Effect runs from the issuance date, 22 June 2026, with no transitional period, so the updated guidance applies immediately on publication.
At the centre of the Decision are three OECD publications, now incorporated as the basis for interpretation in the UAE.
| Publication | Role |
|---|---|
| GloBE Consolidated Commentary (2026) | The consolidated interpretation of the Global Anti-Base Erosion (GloBE) Model Rules |
| Administrative Guidance — Central Record (2026) | The Central Record for the global minimum tax, including qualified-jurisdiction status |
| GloBE Information Return (January 2025) | The standardised reporting form for in-scope MNEs |
Why "consolidated" matters
The shift from several standalone documents to a single 2026 Consolidated Commentary is more than housekeeping. Earlier tranches of administrative guidance and the previous Central Record have been folded into one source, with an integrated Annex B. That reduces the cross-referencing burden, but it also means every internal citation that points to a superseded document is now out of date. Compliance manuals, working papers and tax-technology tools that reference the old guidance need to be re-pointed to the 2026 Commentary so that filing positions rest on the current text.
The rolling Central Record (Annex B)
Annex B — the Central Record of jurisdictions and their qualified status — is updated on a rolling basis rather than through discrete, numbered publications. Jurisdictions can gain or lose qualified status over time, which affects whether rules such as the Income Inclusion Rule (IIR) or a Qualified Domestic Minimum Top-up Tax (QDMTT), and the related safe harbours, apply to a group's entities in a given place. That makes a group's qualified-status map a moving target. In practice, SBC advisers keep a dated Annex B snapshot with each filing, so a later status change can never be read back onto a position that was correct when taken.
Because Annex B changes on a rolling basis rather than through numbered releases, a group's qualified-status map can shift mid-year. Waiting for the next major publication is no longer a safe compliance rhythm — top-up tax modelling has to track the Central Record as it updates.
What in-scope MNEs should do now
The Decision points to a clear set of practical steps for affected groups and their advisers:
- Update internal reference materials, replacing citations to the superseded documents with the three updated publications and aligning everything to the 2026 Consolidated Commentary and its Annex B.
- Re-screen the entity map against the updated Central Record, running a fresh qualified-status check across all jurisdictions where the group has constituent entities, using the current version of Annex B.
- Validate existing filing positions and safe-harbour claims taken in prior periods against the consolidated 2026 guidance, documenting continuity to the equivalent updated text.
- Brief finance and tax-reporting teams — particularly those handling deferred tax, effective-tax-rate calculations and the GloBE Information Return — so they work from the 2026 Commentary as the single reference.
- Set a monitoring protocol for future Central Record updates, assigning responsibility and a review cadence so newly qualifying jurisdictions feed into modelling before they take effect.
Because these steps span tax technical judgement, data and systems, they sit naturally alongside our international tax advisory and tax automation support, integrated with the group's wider corporate tax compliance.
Frequently asked questions
What is Ministerial Decision No. 96 of 2026?
Ministerial Decision No. 96 of 2026 is a UAE decision that adopts the latest OECD commentary and Agreed Administrative Guidance for the country's Top-Up Tax under Cabinet Decision No. 142 of 2024, and repeals the earlier guidance decision, Ministerial Decision No. 88 of 2025.
Does Ministerial Decision No. 96 of 2026 change the UAE Top-Up Tax rate?
No. It updates the interpretive guidance used to calculate and report the Top-Up Tax; it does not change the tax or its rate. The underlying charge remains governed by Cabinet Decision No. 142 of 2024.
When does Ministerial Decision No. 96 of 2026 apply from?
Ministerial Decision No. 96 of 2026 applies to fiscal years starting on or after 1 January 2025 and takes effect from its issuance date, 22 June 2026, with no transitional period, so the updated guidance applies immediately on publication.
What replaced Ministerial Decision No. 88 of 2025?
Ministerial Decision No. 96 of 2026 repeals and fully replaces Ministerial Decision No. 88 of 2025, consolidating the interpretive framework into the three OECD publications adopted in its Annexure: the Consolidated Commentary, the Administrative Guidance Central Record and the GloBE Information Return.
How SBC Tax Consulting can help
SBC helps in-scope multinational groups keep their Pillar Two compliance current under Ministerial Decision No. 96 of 2026. We re-screen entity maps against the updated Central Record, validate prior filing positions and safe-harbour claims, refresh internal reference materials and tax-technology tools, and brief finance teams on the consolidated guidance. To align your group, contact our team or explore our international tax services.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.