Cabinet Decision 142 of 2024 introduced the Domestic Minimum Top-up Tax: a minimum rate of 15%, applying to fiscal years beginning on or after 1 January 2025. The population is defined by size — an Ultimate Parent Entity with consolidated revenue of EUR 750 million or more in at least two of the four immediately preceding fiscal years. Where a fiscal year is shorter or longer than twelve months, the threshold is adjusted proportionally.

One thing the UAE has not done, and it matters for how you read group correspondence: the UAE does not apply the Income Inclusion Rule at this stage. Advice drafted for another jurisdiction's implementation will assume it does, and the assumption is silent rather than stated.

The flag is a screening question, not a computation. It answers whether the group is inside the population. It does not compute a top-up, and nothing in the module claims to. What the flag buys you is knowing that a specialist conversation is due — before the fiscal year closes, rather than after it.

Worked example — the two-of-four test. A group's Ultimate Parent Entity reports consolidated revenue of EUR 690 million in 2021, EUR 780 million in 2022, EUR 720 million in 2023 and EUR 810 million in 2024. For the fiscal year beginning in 2025, the four immediately preceding fiscal years are 2021 to 2024, and two of them, 2022 and 2024, are at or above EUR 750 million. The group is in scope. Note what did not matter: revenue in 2025 itself, and the fact that two of those four years were below the threshold.

Worked example — a short year. A subsidiary changes its year end and reports a seven-month fiscal year. The threshold is adjusted proportionally, so seven twelfths of EUR 750 million gives EUR 437.5 million. A short period does not take a group out of scope; it moves the line the group is measured against.

The failure mode is arithmetic comfort. "We pay 9%, so 15% cannot be our problem" is wrong twice over: the test is on the group's revenue rather than on your rate, and the effective rate that matters is computed under rules that are not the CT Law's. If the flag is on, the next step is advice, not a spreadsheet.