Your UAE entity can be "small" and still be inside Pillar Two.
Most owners I meet treat the UAE's Domestic Minimum Top-up Tax as someone else's problem. "We're nowhere near EUR 750 million."
My position: that instinct is exactly where the damage happens.
The threshold under Cabinet Decision 142 of 2024 is tested at group level — consolidated revenue of EUR 750 million in two of the four preceding fiscal years. Your Dubai entity's own turnover is irrelevant. If your ultimate parent's group crosses the line, your UAE entity is in scope for a 15% minimum effective tax — for financial years starting on or after 1 January 2025.
And the compliance load is not one return. The separate GloBE Information Return can run to 250+ data points per constituent entity.
The owners who get hurt are rarely the ones with big top-up bills. They are the ones who never asked whether the rule applied — because they measured themselves, not their group.
Pillar Two scope is a group-level question — ask it early, not at the deadline.
If your company sits inside a foreign group — do you actually know the group's consolidated revenue for the last four years?
A version of this post was first shared on LinkedIn. Names and figures are anonymised. This is general information, not advice for your business.