Bahrain, the UAE, Kuwait and Qatar have each enacted Domestic Minimum Top-up Tax (DMTT) legislation derived from the OECD's "Pillar Two" framework, all setting the minimum rate at 15% and linking the tax's scope to multinational enterprise groups with consolidated annual revenue of EUR 750 million or more.
Bahrain: the Minimum Rate and the Revenue Threshold
Bahrain's Decree-Law No. (11) of 2024 defines the "minimum rate" as 15%, and confines the tax's scope to multinational enterprise groups whose annual revenue equals or exceeds EUR 750 million in the ultimate parent entity's consolidated financial statements for at least two of the four immediately preceding financial years. The Bahraini law took effect from 1 January 2025.
Kuwait: the Same Rate and Revenue Threshold
Kuwait's Decree-Law No. 157 of 2024 defines the "minimum tax" as an effective tax rate of 15%, and defines the "revenue threshold" as the annual revenue of a multinational enterprise group that equals or exceeds EUR 750 million in the ultimate parent entity's consolidated financial statements for at least two of the four immediately preceding tax periods.
The UAE: Amending the Corporate Tax Law to Introduce the Top-up Tax
The UAE amended its Corporate Tax Law (Federal Decree-Law No. 47 of 2022) through Federal Decree-Law No. 60 of 2023 to enable the imposition of a Qualified Domestic Minimum Top-up Tax (QDMTT), which — according to the Federal Tax Authority's Scope and Registration Top-up Tax Guide — applies to multinational enterprise groups with consolidated revenue of EUR 750 million or more in two of the four preceding financial years, effective for financial years commencing on or after 1 January 2025, to ensure profits are subject to an effective tax rate of at least 15%.
Qatar: the Top-up Tax Regime Under the General Tax Authority's Decision
Qatar's Pillar Two Regulations (Decision No. 2 of 2026) define the "Minimum Rate" as 15%, and set the scope of the Income Inclusion Rule and the Domestic Minimum Top-Up Tax to constituent entities of a multinational entity group with annual revenue of EUR 750 million or more in the ultimate parent entity's consolidated financial statements, applying to fiscal years beginning on or after 1 January 2025, under Article 23 (Bis 8) of the Income Tax Law.
Bahrain's Transitional Safe Harbour: Rates Different From 15%
Bahrain's law provides a transitional safe harbour based on an alternative effective tax rate: 16% for financial years starting in 2025, and 17% for financial years starting in 2026 — meaning groups whose effective tax rate exceeds these transitional rates may not be subject to an additional top-up tax during this phase, even though these rates are slightly higher than the final 15% rate that applies in later years.
Legal References
- Decree-Law No. (11) of 2024 on Taxation of Multinational Enterprises (Bahrain) — definitions of "Minimum Rate" and the revenue threshold test, and Article (44): Entry Into Force
- Decree-Law No. 157 of 2024 on the Tax on Multinational Enterprise Groups (Kuwait) — definitions of "Minimum Tax" and "Revenue Threshold"
- Scope and Registration Top-up Tax Guide | TTGREG1 (UAE Federal Tax Authority) — QDMTT scope, revenue threshold and effective date
- Pillar Two Regulations - Decision No. 2 of 2026 (EN, GTA) (Qatar) — definition of Minimum Rate, revenue threshold and effective date
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