UAE Corporate Tax

Federal Tax Authority Enhances Corporate Tax Return with New Shareholding Disclosure Requirements

The Federal Tax Authority (FTA) has enhanced the Corporate Tax Return on the Emara Tax portal with a new set of disclosure requirements. Taxable Persons are now required to disclose Shareholding Details which requires identification of the Multinational Enterprise (MNE) group, the immediate parent company and the ultimate parent company of the Taxable Person — including their countries of tax residency and tax identification numbers. The earlier disclosure requirement was limited to confirming whether the entity was part of a Multinational Enterprise (MNE) Group or not.

Understanding the New Disclosure Requirements

The new section requires the following disclosures:

While the fields may appear administrative at first glance, their design closely mirrors the information architecture of the UAE's Domestic Minimum Top-up Tax (DMTT) regime under Cabinet Decision No. 142 of 2024. The terminology is deliberate wherein "MNE group," "ultimate parent" and "immediate parent" are concepts drawn directly from the OECD's GloBE framework.

Why this matters: the Pillar Two connection

The UAE's DMTT, effective for fiscal years commencing on or after 1 January 2025, applies to constituent entities of MNE groups with consolidated revenues of EUR 750 million or more in at least two of the four preceding fiscal years — a threshold assessed by reference to the consolidated financial statements of the ultimate parent entity.

With Pillar Two Top-up Tax registration now live on Emara Tax portal, the registration application itself requires detailed information on the MNE group and the ultimate parent entity. The new Corporate Tax Return fields capture precisely this data set.

For entities that complete their Corporate Tax Return before undertaking Pillar Two registration, this data may be reflected into the subsequent Pillar Two registration application on Emara Tax. In either case, the data should be carefully populated if the entity will subsequently register to Pillar Two to avoid any potential mismatches in information.

Taxpayers should therefore treat these fields with the same rigour as any Pillar Two disclosure: the ultimate parent identified here should reconcile with the group's consolidated financial statements, its CbCR filings, and any Pillar Two registrations made in the UAE or elsewhere.

The open question

It is not currently certain as to how this information will be furnished to FTA for the entities that have already filed their Corporate Tax Returns. Further, as the fields relating to information on parent entity and ultimate parent entity are mandatory, there is uncertainty on furnishing of the information in cases where the taxable person is held by an individual wherein the said schedule relating to MNE details may not be applicable.

Recommended actions

1. Map the group structure now
   
   Identify the ultimate parent entity and immediate parent entity, their jurisdictions of tax residency, and their tax identification numbers. For complex structures — intermediate holding companies, trusts, funds, dual-listed groups — the "ultimate parent" determination should follow consolidation principles, consistent with GloBE definitions.
   
   Further, as the Corporate Tax Return filing deadline is nearing and the said fields are mandatory in the Corporate Tax Return, the information should be gathered timely and proactively to avoid any last minute rush.
2. Reconcile across compliance workstreams
   
   The group data disclosed in the Corporate Tax Return should be consistent with CbCR notifications, Pillar Two / DMTT registration data, and transfer pricing documentation. Inconsistencies across these datasets may be readily detectable and may invite additional clarifications/questions from the tax authority.
3. Assess DMTT scope early
   
   Any entity completing the MNE group fields should, in parallel, confirm whether its group meets the EUR 750 million threshold and, if so, progress Pillar Two registration on Emara Tax without waiting for a deadline announcement.
4. Monitor guidance on previously filed returns
   
   Entities that filed the Corporate Tax Returns before the aforesaid update should document their group structure data now so that any future amendment, registration, or FTA information request can be responded to promptly.

Closing observation

The UAE Corporate Tax regime is maturing from a standalone domestic filing obligation into an integrated data ecosystem — one in which the Corporate Tax Return, Pillar Two registration, Transfer Pricing disclosures and treaty positions feed a single, coherent picture of each taxpayer and its global group. The new Shareholding Details section is a small change to the return, but a clear statement of direction: group-level transparency is now a standing feature of UAE tax compliance, and the quality of the data entered today will shape the compliance experience for years to come.

Speak with our Crowe UAE Tax team

At Crowe UAE, our dedicated Corporate Tax team brings together specialists across Corporate Tax, International Tax, and Transfer Pricing, offering an integrated service that addresses every dimension of your tax position — from day-to-day compliance obligations to complex cross-border structuring challenges.