UAE FTA Issues Pillar Two Top-Up Tax Registration Guide and Deadlines

The UAE Federal Tax Authority (FTA) announced that it has published the Top-up Tax Guide on Scope and Registration (TTGREG1). The document details compliance criteria for the UAE Top-up Tax on Multinational Enterprises, also referred to as the Qualified Domestic Minimum Top-up Tax (QDMTT). The tax operates within the UAE Corporate Tax framework under Federal Decree-Law No. 60 of 2023 and Cabinet Decision No. 142 of 2024, applying to fiscal years beginning on or after 1 January 2025 to enforce an effective tax rate of at least 15% under OECD/G20 Pillar Two standards.

Under the guidelines, the tax applies to UAE-based constituent entities of multinational enterprise (MNE) groups with consolidated annual revenues of EUR 750 million or more in at least two of the four fiscal years prior to the tested year. Purely domestic UAE groups without foreign operations remain out of scope regardless of turnover. Exempt entities include government bodies, international organisations, non-profit entities, pension funds, and certain investment vehicles serving as ultimate parent entities.

Registration must be completed on the EmaraTax platform separately from Corporate Tax registration, issuing a distinct Pillar Two Top-up Tax Registration Number (TRN). Under FTA Decision No. 12 of 2026, entities whose first in-scope fiscal year ends before 30 April 2026 must register on or before 30 November 2026. For fiscal years ending on or after 30 April 2026, entities must register within seven months of the fiscal year end. Registration remains mandatory even if an entity's top-up tax liability is deemed zero under de minimis exclusions or safe harbour provisions.

Failure to register within the stipulated timeframe incurs an administrative penalty of AED 10,000 per entity. Groups may register individual entities separately or appoint a Domestic Designated Filing Entity (DDFE) to manage registration, filing, and payment across UAE members.