Case Study
UAE DMTT Impact Assessment Support
Middle East operations have entered an era where "structure design" matters more than "entity establishment."
01 — Background
Background
From 2024 onwards, the UAE introduced federal corporate income tax (CIT 9%) and also implemented the Domestic Minimum Top-up Tax (DMTT) system to comply with OECD BEPS 2.0 Pillar Two (global minimum tax rate of 15%).
Our client:
02 — Challenges
Client Challenges
- 1Unclear consistency between QFZP 0% application and Pillar 2
- 2Management judgment on corporate tax payment and tax amount determination for target fiscal year
- 3Insufficient materials for headquarters explanation
- 4Accounting shows profits
- 50% application is possible in the UAE
- 6Necessity of maintaining QFZP in the future
03 — Our Approach
Biz Easy's Approach
1
Regulatory Mapping
UAE CIT law, QFZP requirements, UAE DMTT system, OECD GloBE rules, relationships with Japan's IIR (Income Inclusion Rule)
2
ETR Simulation
Accounting profit basis, GloBE-adjusted profit, Covered Taxes recalculation, ETR calculation, Top-up Tax estimation
3
Risk Matrix Development
04 — Impact Results
Results
✓
DMTT Impact Assessment Report (approximately 40 pages)✓
Quantitative ETR Simulation Model (Excel)✓
Executive Summary for Management (10 pages)✓
English materials for headquarters presentation✓
Future structure optimization option comparison table
05 — Value Delivered
Value Delivered by Biz Easy
The essence of this project is:
In the Middle East, “structure design” has become more critical than simple entity establishment. Biz Easy provided regulatory interpretation, quantitative ETTR simulation, and practical insights to support headquarters-level decision making.
06 — Ideal For
Ideal For
Utilizing Free Zone 0% application
Global revenue exceeding 750 million EUR
Japan headquarters subject to Pillar 2
DMTT impact not yet thoroughly analyzed
No quantitative analysis provided by tax advisors
07 — Our Strengths
Biz Easy's Strengths
Regulatory
Accounting
Tax
Operations
Governance
Summary
Middle East operations have entered an era where "structure design" matters more than "entity establishment." Biz Easy provides:
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