UAE Issues VAT Fixed Establishment Guidance and Pillar Two Registration Deadlines

Law firm DLA Piper published an analytical briefing on October 30, 2026, outlining key regulatory shifts in the UAE and GCC tax framework. According to the briefing, recent Federal Tax Authority (FTA) guidance cautions non-resident foreign businesses that they may trigger a UAE fixed establishment for VAT purposes even without owning local real estate, particularly when personnel routinely operate from client premises.

The report also reminded international enterprises that UAE constituent entities of multinational groups must register for the Pillar Two Qualified Domestic Minimum Top-up Tax (QDMTT) by November 30, 2026. This deadline applies if their first in-scope fiscal year concluded prior to April 30, 2026.

Pillar Two regulations require affected multinational enterprises to achieve an effective corporate tax rate of at least 15%. DLA Piper advised international firms to review their non-resident VAT exposure and adjust internal data collection systems for upcoming top-up tax reporting.