Global Minimum Tax (Pillar Two) Saudi Arabia
Advisory and compliance support for multinational enterprise groups affected by the OECD Pillar Two global minimum tax framework — including Saudi Arabia's DMTT implementation.
The DMTT ensures that if a Saudi entity's effective tax rate (combining Zakat and CIT) falls below 15%, ZATCA will impose a top-up tax to bring it to the minimum. For Saudi entities that receive Zakat concessions, Vision 2030 incentives, or RHQ tax benefits, the interaction with Pillar Two requires careful modelling. Intelli Solutions provides specialist Pillar Two advisory — impact assessment, GloBE effective tax rate modelling, DMTT calculation, and compliance for affected MNE groups.
Pillar Two Impact for Saudi Arabia Entities
Who Is Affected?
- MNE groups with global revenues ≥ EUR 750M
- Saudi entities that are part of such groups
- Foreign parents with Saudi subsidiaries (IIR applies)
- Saudi parents of low-tax foreign subsidiaries (UTPR)
- RHQ entities enjoying 0% CIT incentives
Key Pillar Two Rules
- DMTT: Saudi domestic top-up tax to 15% minimum
- IIR: Income Inclusion Rule — parent tops up low-taxed subsidiaries
- UTPR: Undertaxed Profits Rule — backstop mechanism
- SBIE: Substance-Based Income Exclusion — carve-out for payroll & tangible assets
- Transitional CbCR Safe Harbour: Available for qualifying groups
Global Minimum Tax Saudi Arabia (Pillar Two) — Key Facts
Frequently Asked Questions — Global Minimum Tax Saudi Arabia (Pillar Two)
Other Tax & Zakat Services
Is Your MNE Group Ready for Pillar Two in Saudi Arabia?
Our Pillar Two specialists model your GloBE effective tax rate and DMTT exposure for Saudi entities. Free scoping call.