UAE Top-up Tax: Who Has to Register and by When
- 28.08.2026
- Posted by: Uwe Hohmann
- Categories: Tax, Dubai
The FTA (Federal Tax Authority) has published its guide on the scope of and registration for the Top-up Tax on multinational enterprises. It confirms which businesses fall inside the rules, and it confirms a registration deadline of 30.11.2026 for a large number of groups.
If your company in the UAE belongs to a large international group, this is a date to put in the calendar now.
What the Top-up Tax actually applies to
The QDMTT (Qualified Domestic Minimum Top-up Tax) legislation was introduced through Cabinet Decision No. 142 of 2024 and applies to fiscal years beginning on or after 01.01.2025. It follows the global minimum tax framework agreed through the OECD (Organisation for Economic Co-operation and Development), and it is designed so that the UAE collects the top-up amount on locally generated profits rather than another country collecting it.
Two conditions decide whether a group is in scope.
1. The entity must be part of an MNE (Multinational Enterprise) Group, meaning a group that operates through at least one entity or permanent establishment outside the jurisdiction of its UPE (Ultimate Parent Entity).
2. The group must have annual revenue of EUR 750 million or more in the consolidated financial statements of the UPE in at least two of the four fiscal years immediately preceding the year being tested.
How the revenue threshold is measured
The test looks backwards at the four preceding fiscal years, and revenue in the year being tested is not part of the calculation. This means a group can cross EUR 750 million this year and still be outside the rules, while a group whose revenue has fallen can remain in scope because of earlier years.
Revenue is taken from the consolidated financial statements, so intra-group revenue that is eliminated on consolidation does not inflate the figure. Where the group reports in a currency other than EUR, the amounts are converted using the average daily reference rates for the December preceding the relevant fiscal year, generally as quoted by the European Central Bank.
Two points regularly catch groups out. Revenue of entities that are themselves outside the charging provision still counts towards the threshold. And the threshold is modified where the group has been through a merger or a demerger, which can pull a business into scope earlier than the standalone figures would suggest.
Who has to register with the FTA
Any entity that is subject to Top-up Tax under the QDMTT legislation has to register with the FTA. Registration is a separate obligation from CIT (Corporate Income Tax) registration. Being registered for CIT, or being inside an existing Corporate Income Tax group, does not cover this. The entity must register for Top-up Tax in its own right.
There are two routes.
Under the entity-by-entity approach, each in-scope entity applies separately and receives its own Pillar Two Top-up Tax TRN (Tax Registration Number).
Under the alternative approach, the group appoints a DDFE (Domestic Designated Filing Entity) from within the relevant domestic group. The DDFE registers on behalf of all the members it represents, and it also takes on the filing of the Top-up Tax Return and payment of the tax for those entities. Each entity being represented has to authorise the appointment, either by acknowledging it directly on the portal or through a signed letter of authorisation.
One point deserves emphasis. Even where the Top-up Tax works out at zero, for example because a safe harbour, the de-minimis rule or the initial phase of international activity applies, the entity is still treated as subject to the charging provision. It still has to register.
Deadlines and the cost of missing them
For a fiscal year ending before 30.04.2026, the registration application must reach the FTA on or before 30.11.2026. For every other case, the application is due within 7 months from the end of the first fiscal year in which the entity comes into scope.
Missing the deadline carries an administrative penalty of AED 10,000. Where a DDFE has been appointed and fails to file the applications on time, the penalty applies for each entity it failed to register, so the exposure for a group with several UAE entities multiplies quickly. The FTA also has the discretion to register an entity itself using the information available to it, with effect from the date the obligation originally arose.
How the registration process works
Applications are submitted through the EmaraTax portal. An entity that is already registered for another tax should use the same Taxable Person profile. An entity with no previous FTA registration first has to create a Taxable Person and a TIN (Tax Identification Number) before it can register for Top-up Tax.
The supporting documents include verification of the name and TIN of the UPE where the UPE sits outside the UAE, the same details for a Designated Filing Entity located outside the UAE, and an overview of the corporate structure of the group. The FTA can request further information before deciding on an application, so incomplete structure charts are a common reason for delay. Where a business wishes to be represented by a tax agent for Top-up Tax purposes, that agent must already be listed with the FTA as a tax agent for Corporate Tax.
What This Means for Your Business
If your UAE company is part of a group with international revenue anywhere near EUR 750 million, the first task is factual rather than technical. Pull the consolidated revenue for the four preceding fiscal years, check how many of them cross the threshold, and confirm whether the group has been through a merger or a restructuring that changes the answer.
From there the work is practical. Identify every group entity located in the UAE, including branches and joint venture members, decide whether to register entity by entity or to appoint a DDFE, collect the authorisations and the structure documentation, and build in time for the FTA to come back with questions.
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