The UAE Federal Tax Authority has reminded multinational groups about an approaching deadline: 30 November 2026 is the registration cut-off for Top-up Tax. The deadline applies to groups within the Qualified Domestic Minimum Top-up Tax (QDMTT) regime whose fiscal year ends before 30 April 2026. Missing the date costs AED 10,000 per UAE entity.
What happened
Earlier this year the FTA issued two main interpretative guides on Top-up Tax: TTGREG1 — Scope and Registration Guide and TTGEIE1 — Excluded Entities and Investment Entities Guide. Both explain how to apply Cabinet Decision No. 142 of 2024 — the instrument that introduced the UAE's Qualified Domestic Minimum Top-up Tax (QDMTT) under the OECD Pillar Two framework. In October the FTA again reminded businesses through the press about the approaching registration cut-off for the first cycle.
Alongside the guides, 2026 brought Ministerial Decision 96/2026 (adopting the OECD Consolidated Commentary on Pillar Two), Ministerial Decision 133/2026 (filing procedure for the Pillar Two Information Return — PIR) and FTA Decision 12/2026 (registration and de-registration of in-scope entities).
Who falls within the Top-up Tax scope
The test is single-barrelled: a multinational group whose Ultimate Parent Entity (UPE) consolidated revenue is EUR 750 million or more in at least two of the four fiscal years immediately preceding the fiscal year under review. The regime applies to fiscal years beginning on or after 1 January 2025.
- In scope: foreign-headquartered MNE groups with UAE entities, subject to the revenue threshold;
- In scope: UAE-headquartered groups with foreign subsidiaries, subject to the threshold;
- Out of scope: groups operating exclusively within the UAE, regardless of revenue;
- Out of scope: all businesses below EUR 750 million — they continue under the standard 9% corporate tax regime.
For excluded categories (governmental and international organisations, pension funds, investment funds, real estate investment vehicles) the FTA has set out detailed criteria in TTGEIE1 — important if your structure includes holding or fund vehicles.
Key deadlines
The general rule is 7 months from the end of the first in-scope fiscal year. For the first cycle the FTA has introduced a transitional deadline: 30 November 2026 for any group whose fiscal year ends before 30 April 2026. So a group with FY ending 31 December 2025 and a group with FY ending 31 March 2026 face the same registration deadline.
On 18 August 2025 the UAE regime was included in the OECD central record with 'transitional qualified' status — meaning that for other jurisdictions the UAE QDMTT is temporarily recognised as a Qualified Domestic Minimum Top-up Tax, excluding parallel top-up charges under the Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR) abroad.
What to do before 30 November 2026
- Confirm scope. Pull the UPE's consolidated financial statements for the last four fiscal years and check whether revenue cleared EUR 750 million in at least two of them.
- Classify entities. Walk through the TTGREG1 checklist for Constituent Entities, Permanent Establishments, Joint Ventures, Flow-through Entities and Hybrid Entities. Separately, test exclusions under TTGEIE1 for investment funds and holding vehicles.
- Appoint a Domestic Designated Filing Entity (DDFE) — one UAE entity of the group responsible for registering the others and submitting the Pillar Two Information Return. A Designated Local Entity may be appointed separately for the sole purpose of filing a single PIR for the UAE sub-group.
- File registration applications through EmaraTax — one per UAE entity, from a single DDFE dossier. UPE details, group structure overview and the Designated Filing Entity location are required inputs.
- Build the PIR data pipeline. The Pillar Two Information Return is a separate reporting instrument, governed by Ministerial Decision 133/2026. Effective-tax-rate data by jurisdiction needs to be collected now, in parallel with preparation for e-invoicing, which the UAE is rolling out in 2026–2027.
The late-registration penalty is AED 10,000 per UAE entity for which the DDFE fails to file on time. For a group with, say, five UAE entities that is AED 50,000 just for missing the deadline — before any PIR non-filing penalties.
Context: Pillar Two in the UAE
Pillar Two is part of the OECD/G20 agreement on a global minimum effective tax rate of 15% for large multinational groups. The UAE has opted for the Qualified Domestic Minimum Top-up Tax model: the top-up is collected locally rather than being transferred to the UPE jurisdiction through the Income Inclusion Rule (IIR) or the Undertaxed Profits Rule (UTPR). This keeps the tax base in the UAE and simultaneously removes the risk of double top-up for businesses.
For the vast majority of companies in the UAE nothing changes — the EUR 750 million threshold filters out SMEs. The corporate tax rate for them is 9% on profit above AED 375,000. Top-up Tax is about Fortune 500 groups, large DIFC/ADGM holdings and local arms of global players. If that is your structure — 30 November 2026 is already on the horizon, and the chance of another FTA extension is minimal: the OECD calendar is synchronised across 140+ jurisdictions.
