Federal Tax Authority Decision No. 12 of 2026 sets deadlines for Tax Registration, tax deregistration and in-scope and out-of-scope notifications for entities subject to the UAE's Top-up Tax, effective for Fiscal Years starting on or after 1 January 2025.
The UAE Federal Tax Authority (FTA) issued Federal Tax Authority Decision No. 12 of 2026, establishing the registration, deregistration and notification requirements for entities subject to the domestic Top-up Tax under Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
The Decision was issued on 16 July 2026, published on 4 August 2026.
Under the Decision, an Entity that is subject to Top-up Tax must submit a Tax Registration application within seven months from the end of the first Fiscal Year in which it falls within the scope of Article 1.1 of the annexure to Cabinet Decision No. 142 of 2024. As a transitional measure, entities with a Fiscal Year ending before 30 April 2026 must complete their Tax Registration on or before 30 November 2026.
Registration and deregistration requirements
The Decision sets deadlines for Tax Deregistration. An Entity must submit a Tax Deregistration application within six months from the earlier of the date it ceases to exist or the end of the Fiscal Year in which it leaves an MNE Group and is no longer within the scope of the Top-up Tax rules. Entities that ceased to exist before 30 June 2026 have until 31 December 2026 to submit their applications.
The FTA said an Entity cannot be deregistered unless it has fully settled all Top-up Tax and penalties due and submitted all required Top-up Tax Returns and Pillar Two Information Returns. Where an eligible Entity fails to apply for deregistration, the Authority may deregister it at its discretion based on the information available.
Notification obligations
The Decision introduces notification requirements for entities moving into or out of scope. A member of an MNE Group that becomes out of scope for a tested Fiscal Year must submit an out-of-scope notification within six months from the end of that Fiscal Year. The notification remains valid for the tested Fiscal Year and the following four consecutive Fiscal Years.
If an Entity becomes subject to the Top-up Tax again while an out-of-scope notification remains valid, it must submit an in-scope notification within seven months from the end of the tested Fiscal Year. Where an out-of-scope notification remains valid for five consecutive Fiscal Years, the Entity must submit a Tax Deregistration application within six months from the end of the fifth Fiscal Year unless it is required to file an in-scope notification.
Domestic designated filing entity
The Decision also specifies that where a Domestic Designated Filing Entity has been appointed under Article 2.2 of the annexure to Cabinet Decision No. 142 of 2024, it is responsible for submitting Tax Registration and Tax Deregistration applications, as well as in-scope and out-of-scope notifications, on behalf of members of a Domestic Main Group, Domestic Minority-owned Subgroup, Reverse Hybrid Entity, or Domestic JV Group.
The Decision applies to fiscal years starting on or after 1 January 2025, abrogates any conflicting provisions, and came into effect on its date of issuance following publication in the Official Gazette.
