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MNE Group Registration & Deregistration for Top-up Tax
In this update
A new registration regime for Domestic Minimum Top-up Tax
The Federal Tax Authority (FTA) has published FTA Decision No. 12 of 2026, setting out the requirements for registering and deregistering entities for the purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises.
The regime applies to Constituent Entities that are part of a Multinational Enterprise (MNE) Group with annual consolidated revenue of EUR 750 million or more in the financial statements of the Ultimate Parent Entity (UPE) for at least two of the four fiscal years immediately preceding the tested fiscal year.
Appointing a Domestic Designated Filing Entity (DDFE)
A DDFE can be appointed to manage DMTT compliance requirements on behalf of all members of:
- Domestic Main Group, Domestic Minority-owned Sub-Group, Reverse Hybrid Entity
- Domestic JV Group
Assess the impact
Identify the steps your entity must take to comply with DMTT requirements.
Select your approach
Centralized registration through a DDFE vs. individual entity registration.
Avoid penalties
An AED 10,000 penalty applies for failure to register.
Prepare your registration early.
Key dates
Pillar Two Compliance Deadlines
Registration, notification and deregistration windows run on parallel clocks — measured from fiscal year-end, from the date an entity falls in or out of scope, or from a fixed calendar date where an exception applies.
Registration & In-Scope Notification
General Rule
Within 7 months of the fiscal year-end.
Exception
FY ending before 30 April 2026: by 30 November 2026.
In-Scope Notification
Within 7 months of becoming in scope.
Deregistration & Out-of-Scope Notification
General Rule
Within 6 months of ceasing to exist or falling out of scope.
Exception
Ceases before 30 June 2026: by 31 December 2026.
Out-of-Scope Notification
Within 6 months of the fiscal year-end.
DLE Appointment
At the time of registration.
Return Filing Deadline
Within 15 months of fiscal year-end. Each UAE entity must file the return.
Ministerial Decision No. 133 of 2026
Filing the Pillar Two Information Return
The Pillar Two Information Return is a separate return from the local Top-up Tax Return. Ministerial Decision No. 133 of 2026 sets out four options for filing it.
Pillar Two Information Return
A standalone filing obligation, distinct from the local Top-up Tax Return, with four routes to meet it.
Each UAE entity must file the return.
A Designated Local Entity (DLE) may file one return on behalf of all the UAE entities.
Filed by the UPE in a jurisdiction with an effective QCAA with the UAE.
Filed by a Designated Filing Entity (DFE) in a jurisdiction with an effective QCAA with the UAE.
Thank you
Speak to Our Pillar Two Specialists
For any inquiries, please feel free to contact:
