UAE Top-up Tax: Scope, Registration Requirements and 2026 Deadlines

The UAE has introduced new tax obligations for large multinational enterprise groups as part of its alignment with international tax standards. Companies operating across multiple countries may now need to assess whether they fall within the scope of UAE Top-up Tax and complete a separate registration with the Federal Tax Authority (FTA).

The UAE's Domestic Minimum Top-up Tax (QDMTT) applies to fiscal years beginning on or after 1 January 2025. It follows the OECD/G20 Pillar Two framework, which aims to establish a minimum effective tax rate of 15% for large multinational groups.

Recent FTA publications clarify which businesses are covered, who must register, and the applicable deadlines.

What Is the UAE Top-up Tax?

UAE Top-up Tax is a domestic minimum tax designed to ensure that qualifying multinational enterprise (MNE) groups are subject to a minimum effective tax rate of 15% on their UAE profits, calculated under the applicable rules.

The framework is established under Cabinet Decision No. 142 of 2024 and forms part of the UAE's implementation of the OECD Pillar Two global minimum tax initiative.

Unlike regular UAE Corporate Tax, which applies more broadly to businesses meeting its conditions, Top-up Tax targets large multinational groups. It also has separate registration and compliance requirements.

Which Businesses Fall Within the Scope of the UAE Top-up Tax?

The UAE Top-up Tax rules apply when two key conditions are satisfied.

1. Multinational Enterprise Group Condition

An MNE Group generally consists of related entities operating across more than one jurisdiction. This includes a UAE-headquartered group with overseas subsidiaries or a foreign multinational with entities or permanent establishments in the UAE.

A standalone UAE company with a qualifying permanent establishment in another country may also meet the MNE Group definition.

However, a business group operating exclusively within the UAE does not fall within the QDMTT scope merely because it generates substantial revenue.

2. EUR 750 Million Revenue Threshold

An MNE Group must have annual consolidated revenue of EUR 750 million or more in at least two of the four fiscal years immediately preceding the relevant fiscal year.

The assessment uses the consolidated financial statements of the Ultimate Parent Entity (UPE), which is generally the highest entity controlling the group.

For example, consider a multinational group with the following consolidated revenue:

For the 2025 fiscal year, the group meets the threshold because its revenue reached EUR 750 million in two preceding years: 2022 and 2024. The revenue of the tested Fiscal Year (2025) is not relevant.

Special calculations may apply to mergers, demergers and fiscal years shorter or longer than 12 months.

Which UAE Entities Must Register for Top-up Tax?

Not every company connected to an MNE Group is automatically required to register. The obligation depends on whether the entity falls within the charging provisions of the QDMTT legislation.

The main categories include:

• UAE Constituent Entities: Companies and permanent establishments located in the UAE that belong to an in-scope multinational group.
• Joint Ventures and JV Subsidiaries: UAE entities meeting the applicable joint venture definitions and ownership conditions.
• Relevant Reverse Hybrid Entities: Certain stateless Constituent Entities created under UAE law and classified as Reverse Hybrid Entities.

Some entities, including qualifying Excluded Entities and Investment Entities, are not subject to Top-up Tax. Their status must be assessed under the applicable legislation.

Importantly, an entity may still need to register even when its calculated Top-up Tax is zero under an applicable safe harbour or simplification provision.

UAE Top-up Tax Registration: Available Approaches

The FTA permits two approaches for completing UAE Top-up Tax registration.

Entity-by-Entity Registration

Under this approach, each UAE entity subject to Top-up Tax submits its own registration application.

Once approved, the FTA issues an individual Pillar Two Top-up Tax Tax Registration Number (TRN) to that entity.

Domestic Designated Filing Entity (DDFE)

An eligible domestic group may appoint a Domestic Designated Filing Entity (DDFE) to register the entities it represents.

The DDFE must belong to the relevant domestic group. It is also responsible for submitting the Top-up Tax Return and paying Top-up Tax on behalf of its represented entities.

Each registered entity receives an individual Pillar Two Top-up Tax TRN, while an additional group-level TRN is issued where applicable.

Separate DDFEs are necessary when an MNE Group adopts this approach for both its Domestic Main Group and Domestic JV Group.

Important UAE Top-up Tax Registration Deadlines for 2026

Businesses must identify the first fiscal year in which they become subject to the QDMTT legislation before determining their registration deadline.

Under FTA Decision No. 12 of 2026, two timelines apply:

For example, if a company's first in-scope fiscal year ends on 31 December 2026, its registration application must be submitted by 31 July 2027.

Companies should not assume the same deadline applies to every entity. Different financial year-ends and changes in group structure can affect the applicable registration timeline.

How to Register for UAE Top-up Tax Through EmaraTax

UAE Top-up Tax registration is completed through the FTA's EmaraTax portal. The process generally involves the following steps:

1. Access the EmaraTax portal.
2. Select the existing Taxable Person profile if already registered with the FTA.
3. Create a Taxable Person profile and obtain a Tax Identification Number (TIN) if the entity has no previous FTA registration.
4. Complete the Top-up Tax registration application.
5. Upload the required supporting documents.
6. Respond to additional information requests, if any.
7. Receive the Pillar Two Top-up Tax TRN following approval.

Documents Required for Registration

According to the FTA guidance, supporting documents include:

• Documents confirming the name and TIN of an overseas Ultimate Parent Entity.
• Documents confirming the name and TIN of an overseas Designated Filing Entity, where applicable.
• Documentation outlining the MNE Group's corporate structure.

Where a DDFE is appointed, each represented entity must authorise the appointment through EmaraTax or a signed authorisation letter.

Important: Existing Corporate Tax registration does not replace UAE Top-up Tax registration. An entity subject to QDMTT must complete the separate registration requirement.

What Is the Penalty for Late UAE Top-up Tax Registration?

Missing the applicable Top-up Tax registration deadline can result in an administrative penalty of AED 10,000.

The FTA guidance also clarifies that when a DDFE fails to submit applications for the entities it represents, the AED 10,000 penalty applies separately to each affected entity.

Therefore, multinational groups should confirm their registration responsibilities early, particularly where several UAE entities fall within the same corporate structure.

How Can Businesses Prepare for UAE Top-up Tax Compliance?

Businesses potentially affected by the UAE Domestic Minimum Top-up Tax should take practical steps to evaluate their obligations.

• Review consolidated financial statements covering the relevant four fiscal years.
• Confirm whether the EUR 750 million revenue threshold is satisfied.
• Identify UAE Constituent Entities, joint ventures and permanent establishments.
• Examine ownership structures and any relevant exclusions.
• Determine whether individual registration or the DDFE approach is suitable.
• Gather the necessary corporate documents and tax identification details.
• Establish the applicable Top-up Tax registration deadline.

Finance teams should also coordinate with overseas parent companies to obtain the financial and ownership information needed for accurate assessments.

Conclusion

UAE Top-up Tax compliance requires more than determining whether a multinational group exceeds the EUR 750 million revenue threshold. Businesses must also examine their international structure, identify UAE entities covered by the legislation, and fulfil their registration requirements within the prescribed timelines.

With the 30 November 2026 registration deadline approaching for relevant fiscal years, affected multinational groups should review their obligations and prepare the necessary documentation.

Need Help with UAE Top-up Tax Registration and Compliance?

A&A Tax Consultants LLC provides professional tax advisory and compliance support to businesses operating in the UAE. Our team can assist with understanding UAE Top-up Tax requirements, reviewing registration obligations and preparing for the applicable compliance process.

Contact us to discuss your UAE Top-up Tax registration requirements.