Article 9 sets out transitional provisions for MNE Groups entering the Pillar Two regime. It defines how deferred tax assets and liabilities are brought into the system, generally at the lower of the minimum rate or domestic rate. The article provides transitional relief for the Substance-based Income Exclusion, offering higher 'carve-out' rates for payroll and tangible assets between 2025 and 2032. It also includes an exemption for the 'initial phase' of international activity for groups with limited cross-border presence, facilitating a gradual implementation of the global minimum tax rules in the UAE.