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UAE Federal Tax Authority Issues Guide on Scope and Registration for Top-Up Tax

The UAE Federal Tax Authority has issued a new guide regarding scope and registration for the Top-up Tax on multinational enterprises. The document supports multinational enterprise groups in understanding obligations under the Qualified Domestic Minimum Top-up Tax regime and OECD/G20 Pillar Two framework. It details in-scope criteria, registration timelines, and reporting requirements ensuring an effective tax rate of at least 15%.

Issuing authority
UAE Federal Tax Authority (FTA)
Jurisdiction
United Arab Emirates
Publication date
October 7, 2026
Stage
Final rule
Official document
Top-up Tax Guide on Scope and Registration
Official source
www.wam.ae

The UAE Federal Tax Authority (FTA) issued a new Top-up Tax Guide on Scope and Registration on October 7, 2026, according to the Emirates News Agency (WAM).

The published guidance supports Multinational Enterprise (MNE) groups in determining their obligations under the Qualified Domestic Minimum Top-up Tax (QDMTT) regime and the OECD/G20 Pillar Two framework.

According to the release, the guide clarifies in-scope conditions to ensure covered multinational groups are subject to an effective corporate tax rate of at least 15%. Additionally, it details registration timelines and tax treatment rules for permanent establishments, joint ventures, and hybrid entities, while providing practical instructions for submitting the mandatory Pillar Two Information Return.

Sources

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