FTA has opened Pillar Two top-up tax registration through the EmaraTax portal, requiring in-scope multinational enterprise groups to prepare registration data and assess compliance obligations, although detailed guidance on registration deadlines and procedures has yet to be issued.
The UAE’s Federal Tax Authority (FTA) has activated Pillar Two top-up tax registration on the EmaraTax portal, requiring in-scope multinational enterprise (MNE) groups to begin assessing their registration obligations and preparing the necessary documentation.
The registration requirement applies to Constituent Entities that are members of an MNE Group with annual revenues of at least EUR 750 million in the consolidated financial statements of the Ultimate Parent Entity in at least two of the four fiscal years preceding the tested fiscal year. Entities may also fall within scope as a result of a merger, acquisition, or demerger.
The registration system allows entities to register individually or through a Domestic Designated Filing Entity (DDFE), which can submit returns and manage administrative obligations on behalf of eligible UAE group members. However, joint ventures, joint venture groups and reverse hybrid entities must register separately where required.
The UAE introduced its Domestic Minimum Top-Up Tax (DMTT) regime under Cabinet Decision No. 142 of 2024, aligning with the OECD Pillar Two Model Rules and establishing a global minimum Effective Tax Rate (ETR) of 15% for qualifying MNE groups.
Although the registration function is now available, the FTA has not yet announced registration deadlines or issued comprehensive guidance on filing procedures, compliance requirements, notifications or penalties. However, entities subject to the rules will be required to file Top-up tax returns separately from Corporate Tax obligations, with the first return for the year ending 31 December 2025 due by 30 June 2027.
