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The UAE applies a Qualified Domestic Minimum Top-up Tax (QDMTT) to large multinational groups for financial years starting on or after 1 January 2025, so that their UAE profits are taxed at an effective rate of at least 15% under the OECD Pillar Two rules. In its Top-up Tax Guide on Scope and Registration (TTGREG1), announced on 7 October 2026, the Federal Tax Authority (FTA) explains who must register and by when. For groups with a 31 December 2025 year end, the deadline is 30 November 2026.
In short: every UAE entity of a multinational group with consolidated revenue of EUR 750 million or more in at least two of the four preceding years must register for Top-up Tax on EmaraTax. Where the first in-scope financial year ended before 30 April 2026, registration is due by 30 November 2026; otherwise within seven months of the end of the first in-scope year. Late registration costs AED 10,000 per entity.
Who is in scope
- Constituent entities located in the UAE that belong to a multinational (MNE) group with annual revenue of EUR 750 million or more in the ultimate parent's consolidated financial statements in at least two of the four financial years immediately before the year in question.
- Groups whose activities are entirely within the UAE are outside the QDMTT, whatever their revenue.
- Excluded entities (unless an election is made to treat them as constituent entities), investment entities located in the UAE, and stateless permanent establishments and tax-transparent entities do not need to register.
- An entity must still register even where its Top-up Tax is deemed to be zero, for example under the de minimis exclusion, the transitional country-by-country reporting safe harbour or the initial phase of international activity rules.
Registration deadlines and penalty
| Situation | Register by |
|---|---|
| First in-scope financial year ended before 30 April 2026 (for example, the year to 31 December 2025) | 30 November 2026 |
| All other cases, including entities that join an in-scope group later | Within 7 months of the end of the first financial year in which the entity is in scope |
| Failure to register on time | AED 10,000 penalty for each entity not registered, including where a designated filing entity fails to register an entity it represents |
If no application is made, the FTA can register the entity itself, effective from the date it should have registered.
How registration works
- Applications are made on EmaraTax. An entity already registered for another UAE tax uses its existing taxable person profile; otherwise it must first create one and obtain a Tax Identification Number.
- A group can appoint a Domestic Designated Filing Entity (DDFE) to register, file the Top-up Tax return and pay the tax for all its UAE members.
- At registration, the group must tell the FTA which entity will file the Pillar Two (GloBE) Information Return. Under Ministerial Decision No. 133 of 2026, each UAE entity can file its own return, or a Designated Local Entity can file one return for the UAE entities.
What groups should do now
- Test group revenue against the EUR 750 million threshold for each of the four preceding years
- List every UAE entity and permanent establishment, and identify any excluded or investment entities
- Decide whether to appoint a DDFE and a Designated Local Entity, and collect authorisations from each UAE entity
- Check that each entity has an EmaraTax profile and TIN
- Submit registrations well before 30 November 2026 for groups with a calendar-year 2025
- Start gathering the data needed for the GloBE Information Return and the Top-up Tax calculation
How Veridian can help
Our tax practice helps Pakistani and Gulf groups with UAE operations map their entities, test the threshold and prepare the Pillar Two data, and our financial reporting team supports the underlying IFRS numbers. Registrations and filings with the FTA are made by the group or through a UAE-registered tax agent. See also our UAE Corporate Tax and VAT guide, or book a consultation.
Official sources
Frequently asked questions
When must UAE entities register for the Top-up Tax?
Where the first in-scope financial year ended before 30 April 2026, such as a year to 31 December 2025, registration is due by 30 November 2026. Otherwise it is due within seven months of the end of the first financial year in which the entity is in scope.
Which groups are subject to the UAE Top-up Tax?
Multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding financial years. Groups that operate only within the UAE are outside the QDMTT, whatever their revenue.
What is the penalty for not registering for the UAE Top-up Tax?
AED 10,000 for each entity that does not register on time, including each entity a designated filing entity fails to register.
This guide is general information based on the law as we understand it on the date shown, not advice for your situation. Tax rules change often — please speak to us before acting on it. See our disclaimer.