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UAE FTA Issues Top-up Tax Guide for MNEs: Scope and Registration

The UAE Federal Tax Authority has issued the Top-up Tax Guide on Scope and Registration — the first formal methodology on how the Qualified Domestic Minimum Top-up Tax (QDMTT) under Pillar Two applies to Multinational Enterprise (MNE) Groups in the UAE: the EUR 750 million consolidated-revenue threshold, which Entities, Permanent Establishments, Joint Ventures and Hybrid Entities fall in scope, and how the Pillar Two Information Return is filed.

Illustration for the article on the release by the UAE Federal Tax Authority (FTA) of the Top-up Tax Guide on Scope and Registration for Multinational Enterprise (MNE) Groups in October 2026. The document explains the scope and registration process under the Qualified Domestic Minimum Top-up Tax (QDMTT) Legislation, part of the OECD/G20 Two-Pillar Solution. The Guide is intended for persons responsible for the tax affairs of Entities that may be members of an MNE Group and for Tax Agents. Key parameters: an Ultimate Parent Entity consolidated annual revenue threshold of EUR 750 million in at least two of the four fiscal years immediately preceding the fiscal year under consideration; a minimum effective tax rate of 15 per cent in each jurisdiction in which the group operates; application of the Top-up Tax to fiscal years beginning on or after 1 January 2025. Legal basis — the Global Anti-Base Erosion (GloBE) Model Rules under Pillar Two issued by the Organisation for Economic Co-operation and Development and the UAE QDMTT Legislation. The United Arab Emirates was listed on the OECD central record on 18 August 2025 with transitional qualified status. Entities in scope include ordinary Entities, Permanent Establishments, Joint Ventures, Flow-through Entities and Hybrid Entities. Groups that conduct their activities exclusively within the UAE are excluded from the QDMTT regardless of revenue. Prepared for Garant.consulting — the business portal on the United Arab Emirates published by Garant Business Consultancy DMCC.

Common questions on this topic

What is Top-up Tax in the UAE and why has the FTA issued a new Guide?

Top-up Tax is a global minimum taxation mechanism for multinational groups under the OECD/G20 Pillar Two (GloBE Model Rules). The UAE has implemented a Qualified Domestic Minimum Top-up Tax (QDMTT) locally: if the effective tax rate of a group within the UAE falls below 15%, the shortfall is topped up domestically rather than captured by a foreign tax authority. The Top-up Tax Guide on Scope and Registration published on 7 October 2026 is the FTA's first formal methodology on how the law applies: who falls in scope, who stays out, how registration is organised and in what timelines, and how different forms of group participation — ordinary Entities, Permanent Establishments, Joint Ventures, Flow-through Entities and Hybrid Entities — are treated. It is intended for persons responsible for the tax affairs of Entities that may form part of an MNE Group and for Tax Agents.

Which UAE entities actually fall under the QDMTT?

Two conditions apply together. First, you are a Constituent Entity of an international group (MNE Group). Second, the Ultimate Parent Entity consolidated revenue is EUR 750 million or more, and this threshold is met in at least two of the four fiscal years immediately preceding the fiscal year under consideration. When both conditions are met, all Constituent Entities of the group located in the UAE come within the QDMTT. The Guide separately walks through the status of Permanent Establishments, Joint Ventures, Flow-through Entities and Hybrid Entities — each has specific nuances for location determination and base calculation. An explicit and important exemption: groups that conduct their activities exclusively within the UAE do not fall within the QDMTT regardless of their revenue — a key point for large domestic business without foreign operations.

From when does Top-up Tax apply in the UAE?

The UAE QDMTT Legislation applies to fiscal years beginning on or after 1 January 2025. This means that the first Top-up Tax cycles have already closed or are closing in 2026 — for groups with a calendar fiscal year that is FY2025. Registration timelines are set out separately in FTA Decision No. 12 of 2026, which covers registration, deregistration and in-scope/out-of-scope notifications. The new Guide on Scope and Registration logically complements Decision 12/2026 — it closes the definitional side; Decision 12/2026 closes the calendar side.

How does Top-up Tax differ from the standard 9% UAE corporate tax?

They are two separate taxes that run in parallel. The 9% corporate tax is the standard federal profit tax applied to most legal persons in the UAE, with an exemption threshold of AED 375,000 of profit and a special 0% regime for Qualifying Free Zone Persons. The Top-up Tax is an overlay that applies only to the largest multinational groups (from EUR 750 million consolidated revenue) and separately collects the shortfall up to a 15% effective rate where, under the GloBE rules, the rate in the UAE falls below the minimum. If your group is below the EUR 750 million threshold — only the 9% rate and your regular corporate tax cycle apply. If above — you pay the 9% corporate tax as usual and additionally assess whether a QDMTT shortfall arises.

What should an MNE Group company do right now?

Five steps. First — determine whether the group is in scope: review the Ultimate Parent Entity's consolidated revenue for FY2021–2024 and FY2022–2025 and check whether the EUR 750 million threshold is met in at least two of the four years. Second — map out all Constituent Entities located in the UAE, including Permanent Establishments, Joint Ventures, Flow-through and Hybrid Entities. Third — cross-check timings against FTA Decision 12 of 2026 for registration or in-scope/out-of-scope notifications. Fourth — read the Top-up Tax Guide on Scope and Registration in full (the FTA's press release explicitly asks for the Guide to be read in its entirety), rather than fragments, so that the types of Entities and their tax location are classified correctly. Fifth — build the GloBE effective tax rate calculation and Pillar Two Information Return preparation into the accounting system. For MNE Groups with activity only in the UAE it is enough to document the fact of being out of scope and preserve the justification.

On 7 October 2026, the UAE Federal Tax Authority (FTA) issued the Top-up Tax Guide on Scope and Registration — a detailed guide for Multinational Enterprise (MNE) Groups on how the Qualified Domestic Minimum Top-up Tax (QDMTT) applies in the UAE. It is the FTA's first formal methodology on scope and registration under Pillar Two: who falls under the law, who stays out, which Entities and structures register, and how the Pillar Two Information Return is filed.

What happened

The FTA issued, through its press service, a notice announcing the release of the Guide, which supports businesses in applying the Top-up Tax in the UAE and in understanding registration obligations under the QDMTT Legislation. The document is explicitly addressed to persons responsible for the tax affairs of Entities that may be members of an MNE Group, and to Tax Agents. The FTA emphasised that the Guide should be read in its entirety to gain a comprehensive understanding of the definitions, requirements and the interaction between the different rules. The Guide is available through the FTA's official website.

Context: the UAE within the OECD/G20 Two-Pillar Solution

The UAE's Top-up Tax forms part of the OECD/G20 Two-Pillar Solution, which addresses the tax challenges arising from the digitalisation of the economy. Pillar Two — through the GloBE Model Rules (Global Anti-Base Erosion) — seeks to ensure that in-scope MNE Groups are subject to an effective tax rate of at least 15% in each jurisdiction in which they operate. Where the actual rate falls below that minimum, a Top-up Tax mechanism makes up the difference.

The UAE has introduced a domestic variant — the Qualified Domestic Minimum Top-up Tax (QDMTT). The logic is straightforward: it is better for the shortfall to be collected in the UAE under local rules than captured by a foreign tax authority through international Pillar Two mechanisms. The QDMTT applies to fiscal years beginning on or after 1 January 2025. On 18 August 2025, the UAE was listed on the OECD central record with «transitional qualified» status — a technical confirmation that the national QDMTT is recognised as consistent with the GloBE standard for the transitional period.

Who is caught: the EUR 750 million threshold and the exemption

The main quantitative test is the consolidated annual revenue of the Ultimate Parent Entity (UPE) of the MNE Group:

  • EUR 750 million or more as reflected in the Consolidated Financial Statements of the UPE;
  • met in at least two of the four fiscal years immediately preceding the fiscal year under consideration.

Where the group meets this threshold, all of its Constituent Entities located in the UAE fall within the QDMTT Legislation. There is a clear exemption spelt out in the law itself: groups that conduct their activities exclusively within the UAE do not fall within the QDMTT regardless of their revenue. For large domestic business with no overseas footprint, this is the critical point: you may technically cross the EUR 750 million line, but with purely UAE-only activity the law does not apply.

Which structures register

The Guide specifically works through non-standard forms of group participation — this is where tax teams and tax agents most often misclassify the map. The scope of the FTA methodology covers:

  • Entities — ordinary legal persons;
  • Permanent Establishments — permanent establishments of foreign structures in the UAE;
  • Joint Ventures — joint ventures;
  • Flow-through Entities — transparent structures where profits are taxed at the participant level;
  • Hybrid Entities — hybrid structures treated as opaque under one body of law and transparent under another.

For each type, the Guide explains how tax location is determined and how registration obligations work. A separate section addresses the filing of the Pillar Two Information Return — the core return under GloBE from which the effective tax rate and, where relevant, Top-up Tax are calculated.

How this sits alongside the 9% corporate tax

The QDMTT is not a replacement for the familiar 9% UAE corporate tax but an additional layer for large multinational groups. For most domestic businesses the regime remains unchanged: a 9% rate on profit above AED 375,000 plus a qualifying 0% regime for Free Zone Persons. A detailed breakdown of the base regime is in our dedicated piece on the UAE corporate tax at 9% above AED 375,000. The release of the Pillar Two methodology does not alter that base — it adds a separate overlay above it for MNE Groups above EUR 750 million.

Registration and timelines

Registration timings under the Top-up Tax are set out in a separate document — FTA Decision No. 12 of 2026, which defines the calendar for registration, deregistration and in-scope/out-of-scope notifications under the QDMTT. The new Guide on Scope and Registration logically complements that Decision: it answers the «who» question, while Decision 12 answers the «when».

For business, this means both documents need to be read together. First the Guide — to work out whether the structure is in scope and how Permanent Establishments, Joint Ventures and Hybrid Entities qualify. Then Decision 12/2026 — to lock down the registration date and the related notifications.

What an MNE Group company should do

  • Test the threshold. Pull the UPE's consolidated financials for FY2021–2024 and FY2022–2025 and check against EUR 750 million — meeting the threshold in any two of the four periods means the group is in scope.
  • Map the UAE Constituent Entities. All group legal entities, permanent establishments, joint ventures, flow-through and hybrid structures. For each — type and tax location.
  • Apply the «UAE-only» test. If the group operates exclusively within the UAE — document this and keep the supporting evidence: the exemption is explicitly written into the law.
  • Reconcile with FTA Decision 12/2026. Registration, deregistration, in-scope/out-of-scope notifications — all follow that document.
  • Embed the GloBE effective tax rate calculation in the accounting system. The Pillar Two Information Return requires comprehensive data that cannot be assembled on the final day.
  • Read the Guide in full. The FTA's own press release stresses that the Guide must be read in its entirety — the definitions, requirements and interactions between the rules only work in the aggregate.

The bigger picture

Pillar Two in the UAE fits into the overall logic of how UAE business regulation in 2026 has evolved over the last two years: first a federal legislative framework (the QDMTT Legislation), then operational FTA decisions (Decision 12/2026 on timings), then interpretive methodologies such as the new Guide on scope and registration. The purpose of this layer is not to tighten the rules but to give business an unambiguous reading of definitions that in the GloBE Model Rules are expressed in international tax language.

Attribution

The primary source is the Federal Tax Authority of the UAE press service (tax.gov.ae). The factual content has been cross-checked against the verbatim coverage in Gulf News Business of 7 October 2026. Key parameters (EUR 750 million threshold, 15% minimum effective tax rate, QDMTT start from 1 January 2025, listing of the UAE on the OECD central record on 18 August 2025 with «transitional qualified» status, scope of Entity types) are taken directly from the FTA text cited there. The Guide itself is published on the FTA's official website.

Topics:TaxesCorporate TaxTop-up TaxPillar TwoQDMTTFTAMNECompliance