قرار مجلس الوزراء رقم (142) لسنة 2024 بشأن فرض الضريبة التكميلية على المؤسسات متعددة الجنسيات

ar · official · sha256:34b58849a2cd131c2e127839344416652a09a1bb81edbe590ee71844f1e0f2f0AR

المادة (1) فرض الضريبة التكميلية يتم فرض الضريبة التكميلية على المؤسسات متعددة الجنسيات وفق الحالات والأحكام والشروط والقواعد والضوابط والإجراءات الواردة في المرفق.

Ссылаются нормы: RevenueThresholdMetInYear, RevenueThresholdYearsCount, TopUpTaxApplies, TopUpTaxEffectiveRate/value/urn%3Aae%3Acorpus%3Aclir%3Acorporate_tax%3Aparam%3Atop-up-tax-effective-rate%23pinned/definition, TopUpTaxRate, TopUpTaxRevenueThreshold/value/urn%3Aae%3Acorpus%3Aclir%3Acorporate_tax%3Aparam%3Atop-up-tax-revenue-threshold%23pinned/definition, TopUpTaxScopeMet

ar · official · sha256:51f50ea04253d803c011c2251455223b6aa5ef901aa9b6c833f329d51c7faf32AR

المادة (2) سريان القرار بالنسبة للسنوات المالية يسري هذا القرار على السنوات المالية التي تبدأ في أو بعد 01 يناير 2025.

Ссылаются нормы: TopUpTaxApplies, TopUpTaxFirstFiscalYearStart/value/urn%3Aae%3Acorpus%3Aclir%3Acorporate_tax%3Aparam%3Atop-up-tax-first-fiscal-year-start%23pinned/definition

ar · official · sha256:c481dd93a505a6e054743701d6bef69ac49cb0f1b8d7c4a145b116798d3fd6dbAR

المادة (3) العمل بأحكام القرار والنشر يُعمل بأحكام هذا القرار من 01 يناير 2025، ويُنشر في الجريدة الرسمية.

en · translation · sha256:06ad7c1304a9a35c6d6ef9b60756f1bf73d641d24b3e526f82e39d68183c52d9EN

Article (1) Levy of the Top-up Tax The top-up tax shall be levied on multinational enterprises in accordance with the cases, terms, conditions, rules, controls and procedures contained in the attachment.

Ссылаются нормы: RevenueThresholdMetInYear, RevenueThresholdYearsCount, TopUpTaxApplies, TopUpTaxEffectiveRate/value/urn%3Aae%3Acorpus%3Aclir%3Acorporate_tax%3Aparam%3Atop-up-tax-effective-rate%23pinned/definition, TopUpTaxRate, TopUpTaxRevenueThreshold/value/urn%3Aae%3Acorpus%3Aclir%3Acorporate_tax%3Aparam%3Atop-up-tax-revenue-threshold%23pinned/definition, TopUpTaxScopeMet

en · translation · sha256:72348b881dec0deb3d7e22c7501b94f58239f8c577699984be03ec3a5f5163dcEN

Article (2) Application of the Resolution to Fiscal Years This Resolution shall apply to fiscal years beginning on or after 1 January 2025.

Ссылаются нормы: TopUpTaxApplies, TopUpTaxFirstFiscalYearStart/value/urn%3Aae%3Acorpus%3Aclir%3Acorporate_tax%3Aparam%3Atop-up-tax-first-fiscal-year-start%23pinned/definition

en · translation · sha256:d5529b55320d7344c1cd22bd1a519330f98d9b48402c88af36557a87b73187a5EN

Article (3) Entry into Force and Publication This Resolution shall enter into force as of 1 January 2025 and shall be published in the Official Gazette.

en · translation · sha256:2f857d552de73ee5fd65b8afa29390717ecfe170370a7c3bf7137b8acb4f8cc7EN

Article 1.1. Scope of this Decision 1.1.1 This Decision shall apply to Constituent Entities that are members of an MNE Group that has annual revenue of EUR 750 million or more in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two of the four Fiscal Years immediately preceding the tested Fiscal Year. Further rules are set out in Article 6.1 which modify the application of the consolidated revenue threshold in certain cases. 1.1.2 If one or more of the Fiscal Years of the MNE Group taken into account for purposes of Article 1.1.1 is of a period other than 12 months, for each of those Fiscal Years the EUR 750 million threshold is adjusted proportionally to correspond with the length of the relevant Fiscal Year.

Ссылаются нормы: RevenueThresholdMetInYear, RevenueThresholdYearsCount, TopUpTaxRevenueThreshold/value/urn%3Aae%3Acorpus%3Aclir%3Acorporate_tax%3Aparam%3Atop-up-tax-revenue-threshold%23pinned/definition, TopUpTaxScopeMet

en · translation · sha256:62a2fc5c8ad140d72485a06674d3751f8f4147296bd89590f19cb0f80dc0bd6dEN

Article 5.1. Determination of Effective Tax Rate 5.1.1 The Effective Tax Rate of the MNE Group with Net Pillar Two Income shall be calculated for each Fiscal Year. The Effective Tax Rate of the MNE Group is equal to the sum of the Adjusted Covered Taxes of each Constituent Entity located in the UAE divided by the Net Pillar Two Income of the UAE for the Fiscal Year. For purposes of Article 5, each Stateless Constituent Entity subject to the provisions of this Decision shall be treated as if it was a single Constituent Entity located in the UAE. 5.1.2 The Net Pillar Two Income of the UAE for a Fiscal Year is the positive amount, if any, computed in accordance with the following formula: 𝑁𝑒𝑡 Pillar Two 𝐼𝑛𝑐𝑜𝑚𝑒 = Pillar Two 𝐼𝑛𝑐𝑜𝑚𝑒 𝑜𝑓 𝑎𝑙𝑙 𝐶𝑜𝑛𝑠𝑡𝑖𝑡𝑢𝑒𝑛𝑡 𝐸𝑛𝑡𝑖𝑡𝑖𝑒𝑠 – Pillar Two 𝐿𝑜𝑠𝑠𝑒𝑠 𝑜𝑓 𝑎𝑙𝑙 𝐶𝑜𝑛𝑠𝑡𝑖𝑡𝑢𝑒𝑛𝑡 𝐸𝑛𝑡𝑖𝑡𝑖𝑒𝑠 Where: (a) the Pillar Two Income of all Constituent Entities is the sum of the Pillar Two Income of all Constituent Entities located in the UAE determined in accordance with Article 3 for the Fiscal Year; and (b) the Pillar Two Losses of all Constituent Entities is the sum of the Pillar Two Losses of all Constituent Entities located in the UAE determined in accordance with Article 3 for the Fiscal Year. 5.1.3 Adjusted Covered Taxes and Pillar Two Income or Loss of Constituent Entities that are Investment Entities are excluded from the determination of the Effective Tax Rate in Article 5.1.1 and the determination of Net Pillar Two Income in Article 5.1.2.

Ссылаются нормы: DmttAggregatePillarTwoIncome, DmttAggregatePillarTwoLosses, DmttEffectiveTaxRate, DmttNetPillarTwoIncomeNil, DmttNetPillarTwoIncomePositive

en · translation · sha256:27a8f6815fcfc71ac1623ccc5f8d649097d9659eee3dc79677a2f92aadfa5f5cEN

Article 5.2. Top-up Tax 5.2.1 The Top-up Tax Percentage for a Fiscal Year shall be the positive percentage point difference, if any, computed in accordance with the following formula: 𝑇𝑜𝑝 𝑢𝑝 𝑇𝑎𝑥 𝑃𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 = 𝑀𝑖𝑛𝑖𝑚𝑢𝑚 𝑅𝑎𝑡𝑒 − 𝐸𝑓𝑓𝑒𝑐𝑡𝑖𝑣𝑒 𝑇𝑎𝑥 𝑅𝑎𝑡𝑒 Where the Effective Tax Rate is the Effective Tax Rate determined in accordance with Article 5.1 for the Fiscal Year. 5.2.2 The Excess Profit for the Fiscal Year is the positive amount, if any, computed in accordance with the following formula: 𝐸𝑥𝑐𝑒𝑠𝑠 𝑃𝑟𝑜𝑓𝑖𝑡 = 𝑁𝑒𝑡 Pillar Two 𝐼𝑛𝑐𝑜𝑚𝑒 − 𝑆𝑢𝑏𝑠𝑡𝑎𝑛𝑐𝑒 𝑏𝑎𝑠𝑒𝑑 𝐼𝑛𝑐𝑜𝑚𝑒 𝐸𝑥𝑐𝑙𝑢𝑠𝑖𝑜𝑛 Where: (a) The Net Pillar Two Income is the Net Pillar Two Income of the UAE determined under Article 5.1.2 for the Fiscal Year; and (b) The Substance-based Income Exclusion is the Substance-based Income Exclusion determined under Article 5.3 for the UAE for the Fiscal Year (if any). 5.2.3 The Top-up Tax for a Fiscal Year is equal to the positive amount, if any, computed in accordance with the following formula: 𝑇𝑜𝑝-𝑢𝑝 𝑇𝑎𝑥 = (𝑇𝑜𝑝-𝑢𝑝 𝑇𝑎𝑥 𝑃𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑥 𝐸𝑥𝑐𝑒𝑠𝑠 𝑃𝑟𝑜𝑓𝑖𝑡) + 𝐴𝑑𝑑𝑖𝑡𝑖𝑜𝑛𝑎𝑙 𝐶𝑢𝑟𝑟𝑒𝑛𝑡 𝑇𝑜𝑝-𝑢𝑝 𝑇𝑎𝑥 Where: (a) The Top-up Tax Percentage is the percentage point difference determined in accordance with Article 5.2.1 for the Fiscal Year; (b) The Excess Profit is the Excess Profit determined in accordance with Article 5.2.2 for the Fiscal Year; and (c) The Additional Current Top-up Tax is the amount determined, or treated as Additional Current Top-up Tax, under Article 4.1.5 or Article 5.4.1 for the Fiscal Year. 5.2.4 Unless a Domestic Designated Filing Entity has been appointed to pay the Top-up Tax or except where Article 5.4.2 applies, the Top-up Tax of a Constituent Entity shall be determined for each Constituent Entity located in the UAE that has Pillar Two Income determined in accordance with Article 3 for the Fiscal Year included in the computation of Net Pillar Two Income of the UAE in accordance with the following formula: Pillar Two 𝐼𝑛𝑐𝑜𝑚𝑒 𝑜𝑓 𝑡ℎ𝑒 Constituent Entity 𝑇𝑜𝑝 𝑢𝑝 𝑇𝑎𝑥 𝑜𝑓 𝑎 Constituent Entity = 𝑇𝑜𝑝 𝑢𝑝 𝑇𝑎𝑥 X 𝐴𝑔𝑔𝑟𝑒𝑔𝑎𝑡𝑒 Pillar Two 𝐼𝑛𝑐𝑜𝑚𝑒 𝑜𝑓 𝑎𝑙𝑙 Constituent Entities Where: (a) The Top-up Tax is the Top-up Tax determined in accordance with Article 5.2.3 for the Fiscal Year; (b) The Pillar Two Income of the Constituent Entity is the Pillar Two Income of the Constituent Entity located in the UAE determined in accordance with Article 3.2 for the Fiscal Year; (c) The aggregate Pillar Two Income of all Constituent Entities is the aggregate Pillar Two Income of all Constituent Entities located in the UAE that have Pillar Two Income for the Fiscal Year included in the computation of Net Pillar Two Income in accordance with Article 5.1.2. 5.2.5 Where a Domestic Designated Filing Entity has not been appointed to pay the Top-up Tax, the Top-up Tax is attributable to a recalculation under Article 5.4.1 and there is no Net Pillar Two Income in the UAE for the current Fiscal Year, the Top-up Tax shall be allocated using the formula in Article 5.2.4 based on the Pillar Two Income of the Constituent Entities in the Fiscal Years for which the recalculations under Article 5.4.1 were performed. 5.2.6 Where the Effective Tax Rate computed in accordance with Article 5.1.1 is less than zero and the Top-up Tax Percentage computed in accordance with Article 5.2.1 is above the Minimum Rate, the following provisions shall apply: (a) the Excess Negative Tax Expense shall be excluded from its aggregate Adjusted Covered Taxes and an excess negative tax expense carry-forward shall be established; (b) the Excess Negative Tax Expense for a Fiscal Year is equal to the negative Adjusted Covered Taxes for that Fiscal Year; (c) the excess negative tax expense carry-forward must be utilised in all relevant subsequent computations of the Jurisdictional Effective Tax Rate; (d) in each subsequent Fiscal Year in which there is positive Pillar Two Income and Adjusted Covered Taxes in the UAE, the aggregate Adjusted Covered Taxes shall be reduced (but not below to zero) by the remaining balance of the excess negative tax expense carry-forward and such carry-forward shall be reduced by the same amount; (e) the excess negative tax expense attributable to an amount of a loss that is carried back and applied against income for prior taxable years for domestic tax purposes must be taken into account in the current Fiscal Year under Article 5.2.1 and cannot be included in the excess negative tax expense carry-forward; (f) the excess negative tax expense carry-forward shall remain an attribute of a transferor group where the MNE Group disposes of one or more Constituent Entities in the UAE; (g) where the MNE Group disposes of all Constituent Entities in the UAE and reacquires or establishes Constituent Entities in the UAE in a subsequent Fiscal Year, the balance of the excess negative tax expense carry-forward shall be taken into account in determining the Adjusted Covered Taxes for the UAE beginning with such Fiscal Year; (h) the MNE Group shall maintain a record of the outstanding balance of the excess negative tax expense carry-forward.

Ссылаются нормы: DmttExcessProfitNil, DmttExcessProfitPositive, DmttTopUpPercentageNil, DmttTopUpPercentagePositive, DmttTopUpTax, DmttTopUpTaxAllocated

en · translation · sha256:db1d3112894335cb2778ab03bc3a23fd5a4d49089dff374460d945ff1a3d903dEN

Article 5.3. Substance-based Income Exclusion 5.3.1 The Net Pillar Two Income for the UAE shall be reduced by the Substancebased Income Exclusion of the UAE to determine the Excess Profit for purposes of computing the Top-up Tax under Article 5.2. A Filing Constituent Entity of an MNE Group may make an Annual Election not to apply the Substance-based Income Exclusion by not computing the exclusion or claiming it in the computation of Top-up Tax in the Top-up Tax Return filed for the Fiscal Year. 5.3.2 The Substance-based Income Exclusion amount is the sum of the payroll carve-out and the tangible asset carve-out for each Constituent Entity, except for Constituent Entities that are Investment Entities, located in the UAE. 5.3.3 The payroll carve-out for a Constituent Entity located in the UAE is equal to 5% of its Eligible Payroll Costs of Eligible Employees that perform activities for the MNE Group in the UAE, except Eligible Payroll costs that are: (a) capitalised and included in the carrying value of Eligible Tangible Assets; (b) attributable to a Constituent Entity’s International Shipping Income and Qualified Ancillary International Shipping Income under Article 3.3.5 that is excluded from the computation of Pillar Two Income or Loss for the Fiscal Year. 5.3.4 The tangible asset carve-out for a Constituent Entity located in the UAE is equal to 5% of the carrying value of Eligible Tangible Assets located in the UAE. Eligible Tangible Assets means: (a) property, plant, and equipment located in the UAE; (b) natural resources located in the UAE; (c) a lessee’s right of use of tangible assets located in the UAE; and (d) a licence or similar arrangement from the government for the use of immovable property or exploitation of natural resources that entails significant investment in tangible assets. For this purpose, the tangible asset carve-out computation shall not include the carrying value of property (including land or buildings) that is held for sale, lease or investment. The tangible asset carve-out computation shall not include the carrying value of tangible assets used in the generation of a Constituent Entity’s International Shipping Income and Qualified Ancillary International Shipping Income (i.e. ships and other maritime equipment and infrastructure). The carrying value of tangible assets attributable to a Constituent Entity’s excess income over the cap for Qualified Ancillary International Shipping Income under Article 3.3.4 shall be included in the tangible asset carve-out computation. 5.3.5 The computation of carrying value of Eligible Tangible Assets for purposes of Article 5.3.4 shall be based on the average of the carrying value (net of accumulated depreciation, amortisation, depletion, or impairment losses and including any amount attributable to capitalisation of payroll expense) at the beginning and ending of the Reporting Fiscal Year as recorded for the purposes of preparing the Consolidated Financial Statements of the Ultimate Parent Entity. 5.3.6 For purposes of Articles 5.3.3 and 5.3.4, the Eligible Payroll Costs and Eligible Tangible Assets of a Constituent Entity that is a Permanent Establishment are those included in its separate financial accounts as determined by Article 3.4.1 and adjusted in accordance with Article 3.4.2, provided that the Eligible Employees and Eligible Tangible Assets are located in the Jurisdiction where the Permanent Establishment is located. The Eligible Payroll Costs and Eligible Tangible Assets of a Permanent Establishment are not taken into account for the Eligible Payroll Costs and Eligible Tangible Assets of the Main Entity. The Eligible Payroll Costs and Eligible Tangible Assets of a Permanent Establishment whose income has been wholly or partly excluded in accordance with Articles 3.5.3 and 7.1.4 are excluded from the Substancebased Income Exclusion computations of the MNE Group in the same proportion. 5.3.7 For purposes of Articles 5.3.3 and 5.3.4, Eligible Payroll Costs and Eligible Tangible Assets of a Flow-through Entity that are not allocated under Article 5.3.6 are allocated as follows: (a) if the Financial Accounting Net Income or Loss of the Flow-through Entity has been allocated to the Constituent Entity-owner under Article 3.5.1(b), then the Entity’s Eligible Payroll Costs and Eligible Tangible Assets are allocated in the same proportion to the Constituent Entityowner provided it is located in the Jurisdiction where the Eligible Employees and Eligible Tangible Assets are located; (b) if the Flow-through Entity is the Ultimate Parent Entity, then Eligible Payroll Costs and Eligible Tangible Assets located in the Jurisdiction where the Ultimate Parent Entity is located are allocated to it and reduced in proportion to the income that is excluded under Article 7.1.1; and (c) all other Eligible Payroll Costs and Eligible Tangible Assets of the Flowthrough Entity are excluded from the Substance-based Income Exclusion computations of the MNE Group. 5.3.8 A Filing Constituent Entity may claim only a subset of the total Eligible Payroll Costs and Eligible Tangible Assets when calculating the Substance-based Income Exclusion amount under the provisions of this Decision. 5.3.9 Eligible Payroll Costs and Eligible Tangible Assets attributable to income excluded under Article 7.2.1 shall be excluded from the computation of the Substance-based Income Exclusion. The amount excluded under this provision is equal to the total Eligible Payroll Costs and total carrying value of the Eligible Tangible Assets multiplied by the ratio of the Pillar Two Income excluded under Article 7.2.1 to the total Pillar Two Income determined for the Ultimate Parent Entity before the exclusion under Article 7.2.1. 5.3.10 For purposes of Article 5.3.3, a Constituent Entity employer located in the UAE will be entitled to 100% of the Eligible Payroll Costs of an Eligible Employee where such employee undertakes more than 50% of its activities for the Constituent Entity employer during the relevant Fiscal Year within the UAE. Where an Eligible Employee undertakes 50% or less of its activities for its Constituent Entity employer during the relevant Fiscal Year within the UAE, the Constituent Entity employer will be entitled to the proportional Eligible Payroll Costs in accordance with the following formula: 𝑃𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛𝑎𝑙 𝐸𝑙𝑖𝑔𝑖𝑏𝑙𝑒 𝑃𝑎𝑦𝑟𝑜𝑙𝑙 𝐶𝑜𝑠𝑡𝑠 = 𝐸𝑙𝑖𝑔𝑖𝑏𝑙𝑒 𝑃𝑎𝑦𝑟𝑜𝑙𝑙 𝐶𝑜𝑠𝑡𝑠 𝑥 (𝑊𝑜𝑟𝑘 𝑇𝑖𝑚𝑒 𝑖𝑛 𝑡ℎ𝑒 𝑈𝐴𝐸)/(𝑇𝑜𝑡𝑎𝑙 𝑊𝑜𝑟𝑘 𝑇𝑖𝑚𝑒) Where: (a) Eligible Payroll Costs means the total Eligible Payroll Costs of the Eligible Employee that performs activities for the MNE Group for the relevant Fiscal Year. (b) Work Time in the UAE means the total of time that the Eligible Employee worked for the Constituent Entity employer located in the UAE during the relevant Fiscal Year. (c) Total Work Time means the total of time that the Eligible Employee worked for the Constituent Entity employer during the relevant Fiscal Year. 5.3.11 Where Article 5.3.4 applies with respect to an Eligible Tangible Asset of a Constituent Entity owner or lessee located in the UAE, such Constituent Entity will be entitled to 100% of the carrying value of an Eligible Tangible Asset where more than 50% of the time, during the relevant Fiscal Year, the asset is located within the UAE. Where an Eligible Tangible Asset is located within the UAE 50% or less of the time during the relevant Fiscal Year, the Constituent Entity owner or lessee will be entitled to the proportional carrying value of the Eligible Tangible Asset in accordance with the following formula: Time in the Proportional Carrying Value of the Eligible = Eligible Tangible x UAE Asset Tangible Asset Total Time Where: (a) Eligible Tangible Asset means the total carrying value of Eligible Tangible Asset of the Constituent Entity owner or lessee for the relevant Fiscal Year. (b) Time in the UAE means the total of time that the Eligible Tangible Asset was located in the UAE during the relevant Fiscal Year. (c) Total Time means the total time that the Eligible Tangible Asset was owned by the Constituent Entity owner or leased by the Constituent Entity lessee during the relevant Fiscal Year. 5.3.12 For purposes of Articles 5.3.4 and 5.3.5, the following provisions apply in the case of an operating lease: (a) if a lessee does not recognise a right-of-use asset with respect to a leased asset in its financial accounts, a fictional or hypothetical right-of-use asset cannot be created for purposes of the Pillar Two Rules; (b) the lessor will be allowed to take a portion of the carrying value of an asset into account for computing the amount of its Eligible Tangible Asset if the lessor and the asset are located in the UAE in accordance with Articles 5.3.4 and 5.3.11; (c) the amount referred to in paragraph (b) is equal to the excess, if any, of the lessor’s average carrying value of the asset determined at the beginning and end of the Fiscal Year over the average amount of the lessee’s right of use asset determined at the beginning and end of the Fiscal Year; (d) for purposes of paragraph (c), if the lessee is not a Constituent Entity, the lessee’s right-of-use asset shall be equal to the un-discounted amount of payments remaining due under the lease, including any extensions that would be taken into account in determining a right-of-use asset under the financial accounting standard used to determine the Financial Accounting Net Income or Loss of the lessor; (e) in the case of a short-term rental asset, the lessee’s right-of-use asset shall be deemed to be nil; (f) for purposes of paragraph (e), a short-term rental asset is an asset that is regularly leased several times to different lessees during the Fiscal Year and the average lease period, including any renewals and extensions, with respect to each lessee is 30 days or less. 5.3.13 For purposes of Article 5.3.5, the carrying value of an asset shall: (a) not include any increases and any subsequent incremental increase in depreciation resulting from the revaluation model; (b) take into account adjustments that derive from purchase price allocation as a result of the acquisition of an Ownership Interest in an Entity by a member of the Group; and (c) not take into account adjustments that derive from inter-company sales.

Ссылаются нормы: DmttCarveOutRatesAfterTransition, DmttPayrollCarveOut, DmttSubstanceBasedIncomeExclusion, DmttTangibleAssetCarveOut

en · translation · sha256:4d71b8b6a686d7a5ac75a5e4887b5b9aa4a0c7d07d418d92e3df782c7dcd5b66EN

Article 9.2. Transitional relief for the Substance-based Income Exclusion 9.2.1 For the purposes of applying Article 5.3.3, the value of 5% shall be replaced with the value set out in the table set out below for each Fiscal Year beginning in each of the following calendar years: Fiscal Year Beginning In Article 5.3.3 Rate 2025 9.6% 2026 9.4% 2027 9.2% 2028 9.0% 2029 8.2% 2030 7.4% 2031 6.6% 2032 5.8% 9.2.2 For the purposes of applying Article 5.3.4, the value of 5% shall be replaced with the value set out in the table set out below for each Fiscal Year beginning in each of the following calendar years: Fiscal Year Beginning In 2025 2026 2027 2028 2029 2030 2031 2032 Article 5.3.4 Rate 7.6% 7.4% 7.2% 7.0% 6.6% 6.2% 5.8% 5.4%

Ссылаются нормы: DmttCarveOutRates2025, DmttCarveOutRates2026, DmttCarveOutRates2027, DmttCarveOutRates2028, DmttCarveOutRates2029, DmttCarveOutRates2030, DmttCarveOutRates2031, DmttCarveOutRates2032, DmttCarveOutRatesAfterTransition, DmttPayrollCarveOut, DmttTangibleAssetCarveOut