UAE Top-up Tax: Registration and Deregistration Requirements and timelines

The Federal Tax Authority’s Decision No. 12 of 2026 sets out the registration and deregistration requirements for entities within the scope of the UAE top-up tax rules under Cabinet Decision No. 142 of 2024. Issued on 16 July 2026 and effective for fiscal years starting on or after 1 January 2025, the Decision provides much-needed administrative clarity for multinational enterprise groups and other affected entities. It also aligns the practical filing process with the broader UAE Pillar Two framework, helping businesses understand when registration, deregistration, and notification obligations arise.

Under the Decision, entities subject to top-up tax must submit a tax registration application within seven months from the end of the first fiscal year in which they fall in scope. For entities with a fiscal year ending before 30 April 2026, the deadline is extended to 30 November 2026. The Decision also requires deregistration applications to be submitted within six months from the earliest of the date the entity ceases to exist or the end of the fiscal year in which it leaves the MNE group and is no longer in scope. These timelines are designed to support orderly compliance and to reduce uncertainty for taxpayers managing transitional obligations.

The Decision further links deregistration to full compliance, stating that an entity cannot be deregistered unless all top-up tax liabilities and penalties are settled and all required returns have been filed. It also introduces rules for in-scope and out-of-scope notifications, including a mechanism for entities that move in and out of scope over consecutive fiscal years. For domestic group structures, a Domestic Designated Filing Entity may submit the relevant registration, deregistration, or notification on behalf of group members, simplifying administration for eligible businesses. Overall, the Decision provides a clear compliance roadmap for groups affected by the UAE’s top-up tax regime.