Archive · 7 Sep 2026
UAE Minimum Tax Pushes Indian Groups Toward Substance
The UAE is introducing a new minimum tax for very large international companies.
These companies must pay at least 15% tax on profits earned in the UAE.
Smaller businesses are not affected.
This makes the UAE’s tax advantage smaller than before.
Companies that use Dubai for real offices, factories, workers, and trade may still find it useful.
Companies that mainly use UAE entities to hold investments or move money may reconsider them.
The change follows an international plan called Pillar Two.
India’s GIFT City could attract more business by offering reliable and convenient financial services.
The main lesson is that businesses may choose locations for real economic strengths, not just low taxes.
The UAE’s Domestic Minimum Top-up Tax applies a 15% effective rate to qualifying multinational groups with global revenue of at least €750 million.
The November 30 registration deadline is prompting large Indian business groups to reassess UAE entities and structures.
Dubai remains attractive for trade, logistics, finance, connectivity, talent, and regulatory predictability despite the narrower tax advantage.
Indian companies using UAE entities mainly for holding investments, routing transactions, or booking low-tax income face the greatest pressure to restructure.
India’s GIFT City could benefit if it competes through faster services, deeper products, and regulatory certainty rather than additional tax concessions.
- Who
- Large multinational groups, including Indian companies with UAE entities, are affected.
- What
- The UAE’s Domestic Minimum Top-up Tax is introducing a 15% effective minimum tax on qualifying UAE profits.
- When
- The registration deadline is November 30; the article does not specify the year.
- Where
- The measure applies in the United Arab Emirates, including Dubai, while India’s GIFT City is presented as a potential competitor.
- Why
- The tax is intended to reduce the benefit of booking profits in low-tax jurisdictions and make genuine economic activity more important.
Dubai’s Commercial Strengths
Pressure on Low-Substance Structures
Impact of the new tax
Dubai’s Commercial Strengths
Dubai should remain attractive to companies conducting genuine trade or regional operations because of its ports, finance, logistics, connectivity, capital mobility, talent, and regulatory predictability.
Pressure on Low-Substance Structures
Entities primarily used to hold investments, route transactions, or book income at low rates will have less reason to remain, because the tax advantage is narrowing.
India’s competitive response
Dubai’s Commercial Strengths
India can use GIFT City to attract regional headquarters and financial activity by improving speed, product depth, and regulatory certainty.
Pressure on Low-Substance Structures
Creating new concessions to match the UAE could simply replace one subsidy race with another and undermine the purpose of the global minimum tax.
- Minimum effective rate
- 15% on qualifying UAE profits
- Revenue threshold
- €750 million or more in consolidated global revenue
- UAE standard corporate rate
- 9%
- Qualifying free-zone income
- Previously eligible for a 0% rate
- Registration deadline
- November 30
- India-UAE non-oil trade
- More than $76 billion
- Trade growth
- 17% during a difficult global year
- Long-term trade target
- $200 billion by 2032