The UAE Federal Tax Authority has switched on Pillar Two Top-up Tax registration inside the EmaraTax portal. In-scope multinational groups can register now — even though the FTA has not yet fixed an official deadline.
What happened
The Federal Tax Authority (FTA) has activated the Pillar Two Top-up Tax registration module on EmaraTax (tax.gov.ae). The functionality went live around 19 June 2026, with a formal industry-facing announcement circulating on 3 July 2026.
Registration is open. A hard deadline is not. The FTA has confirmed that comprehensive compliance guidance — filing procedures, notification triggers, penalty-framework detail — is still to be published. For now, only the registration channel itself is live.
The move rests on two instruments. Cabinet Decision No. 142 of 2024 introduced the UAE Domestic Minimum Top-up Tax (DMTT) — a Qualified Domestic Minimum Top-up Tax in OECD terminology — with a 15% minimum effective tax rate for in-scope groups, applying to fiscal years starting on or after 1 January 2025. Ministerial Decision No. 96 of 2026, signed on 22 June 2026 by Mohamed bin Hadi Al Hussaini, Minister of State for Financial Affairs, brings the UAE regime into line with the latest OECD Commentary and Administrative Guidance on Pillar Two. It supersedes Ministerial Decision No. 88 of 2025, though the GloBE Information Return template survives unchanged.
Who is in scope
UAE DMTT applies to Constituent Entities of large MNE groups. The trigger is the OECD-standard revenue threshold: the Ultimate Parent Entity (UPE) must report consolidated annual revenue of EUR 750 million or more in at least two of the four preceding fiscal years.
In practice, that captures a wide range of UAE structures:
- Constituent Entities of in-scope MNE groups — mainland and Free Zone alike.
- Free Zone entities, including those with Qualifying Free Zone Person (QFZP) status.
- UAE Permanent Establishments (PEs) of foreign entities.
- Joint ventures — which register separately from the main group.
- Flow-through entities within the group perimeter.
Investment entities sit in a nuanced position. They are excluded from DMTT itself, but their revenue still counts towards the EUR 750 million group threshold. And a UAE Free Zone footprint does not switch off Pillar Two — QFZP 0% relief and the 15% top-up sit in different logical layers.
Data to prepare for registration
EmaraTax expects both group-level and entity-level information at the point of registration, according to the UAE Federal Tax Authority. Assembling it upfront turns registration into a single sitting rather than a stop-start exercise.
What the FTA asks for:
- MNE Group legal name and fiscal year start and end dates.
- UPE details — legal name, jurisdiction of tax residence, Tax Identification Number (TIN).
- For each UAE Constituent Entity — TIN and classification: regular entity, Permanent Establishment, Excluded Entity, or Investment Entity.
- A corporate structure overview visualising controlling interests — up to five PDF or DOC files, maximum 15 MB each.
- Where the group elects to file centrally: a Domestic Designated Filing Entity (DDFE) authorisation letter. Nominated Constituent Entities have 14 business days to accept or reject the DDFE designation via EmaraTax.
Filing timeline: first return and transitional window
The first UAE DMTT return covers fiscal year 2025. For groups on a calendar year ending 31 December 2025, the return is due by 30 June 2027 — an 18-month transitional window aligned with OECD practice.
Subsequent returns follow the standard Pillar Two cadence: within 15 months of fiscal year-end.
The FTA has also carved out a penalty-relief window. For fiscal periods starting on or before 31 December 2026 and ending no later than 30 June 2028, no penalties apply — provided the group can demonstrate a genuine effort to comply. That mirrors the OECD transitional penalty-relief concept: reasonable positions taken in good faith on unresolved technical questions are not punished.
What to do now
Even without a fixed registration deadline, the practical calendar is short. Five steps warrant attention this quarter.
- Confirm scope. Test the EUR 750 million UPE consolidated revenue trigger against the last four fiscal years. If two of them cross the threshold, the group is in.
- Map UAE Constituent Entities. Inventory every UAE presence — mainland companies, Free Zone entities (QFZP included), Permanent Establishments, joint ventures, flow-through vehicles. Classify each one against the EmaraTax categories.
- Decide the filing model. Choose between decentralised filing (each entity registers and files) or centralised filing via a Domestic Designated Filing Entity. Prepare the DDFE authorisation letter and secure the 14-business-day acceptances early — the clock runs inside EmaraTax.
- Pre-assemble the registration pack. Corporate structure charts within the 5-file × 15 MB limit, UPE identifiers, entity TINs, fiscal year dates, DDFE letter if applicable. Enter the portal once the pack is complete rather than iterating on it.
- Run a Pillar Two ETR simulation. Model the Effective Tax Rate for each UAE Constituent Entity on GloBE principles. Identify entities where the ETR sits below 15% — those are the sources of any UAE top-up liability. Bring the Substance-Based Income Exclusion (SBIE) and transitional safe harbours into the model before drawing conclusions.
UAE's position in the OECD Pillar Two framework
UAE DMTT is the domestic collection channel for OECD Pillar Two inside the UAE. Where an in-scope group's ETR on UAE-sourced profits falls below 15%, the top-up is collected in the UAE — instead of being routed to the UPE jurisdiction via the Income Inclusion Rule (IIR) or reallocated to other jurisdictions via the Undertaxed Payments Rule (UTPR).
For the group, this is neutral on total tax charged and materially better on tax certainty. The liability is settled with a single administration under a known rule set, rather than allocated across multiple jurisdictions applying overlapping OECD mechanisms on the same profits.
Ministerial Decision No. 96 of 2026 anchors the UAE regime to the current OECD Commentary and Administrative Guidance. That alignment matters: it is what allows UAE DMTT to qualify as a Qualified Domestic Minimum Top-up Tax — the technical status that switches off IIR and UTPR top-up in other jurisdictions on the same UAE profits. The UAE is now moving in step with the global Pillar Two mechanism, not around it.
Sources
- UAE Federal Tax Authority (FTA) — tax.gov.ae (EmaraTax portal and news centre).
- UAE Ministry of Finance (MoF) — mof.gov.ae (Ministerial Decision No. 96 of 2026).
- uaelegislation.gov.ae — Cabinet Decision No. 142 of 2024.
