The UAE’s Qualified Domestic Minimum Top-up Tax (QDMTT) applies to Fiscal Years beginning on or after 1 January 2025. As part of the UAE’s implementation of OECD Pillar Two, the rules introduce specific scope, registration and reporting requirements for qualifying multinational enterprise (MNE) groups.
The FTA’s Top-up Tax Guide – Scope and Registration (TTGREG1), issued in August 2026, provides guidance on determining whether an MNE Group falls within the QDMTT framework and how UAE entities should approach registration.
Are you in scope?
A practical assessment can be made through the following decision journey:
| Question | YES | NO |
|---|---|---|
| 1. Is the Group multinational? Is at least one Entity or Permanent Establishment located outside the jurisdiction of the UPE? | Proceed to the revenue test. | Outside QDMTT scope. A purely domestic UAE Group is not an MNE Group for these purposes. |
| 2. Is the EUR 750m threshold met? Did consolidated revenue reach at least EUR 750 million in 2 of the 4 preceding Fiscal Years? | Proceed to identify the relevant UAE entities. | Outside QDMTT scope for the tested Fiscal Year. |
| 3. Is the UAE Entity subject to the charging provisions? | Proceed to registration assessment. | Consider whether it is an Excluded Entity, Investment Entity or other Entity outside the charging provisions. |
| 4. Is Top-up Tax deemed to be zero under an applicable relief or safe harbour? | Registration may still be required. | If the Entity is subject to Top-up Tax, registration is required. |
When must you register
| FIRST FISCAL YEAR IN SCOPE | DEADLINE |
|---|---|
| Ends before 30 April 2026 | 30 NOVEMBER 2026 |
| All other cases | Within 7 months after the end of the first in-scope fiscal year |
Who may need to register?
For an in-scope MNE Group, the registration population may include:
- UAE Constituent Entities
- Permanent Establishments
- Minority-Owned Constituent Entities
- Joint Ventures & JV Subsidiaries
- Certain Reverse Hybrid Entities
Entity classification is important. Excluded Entities, Investment Entities and certain Stateless Constituent Entities are not subject to Top-up Tax and are generally not required to register, however, as mentioned above, their revenue still counts for Euro 750 mn threshold.
Zero Top-up Tax does not necessarily mean no registration
An Entity may remain subject to registration even where its Top-up Tax is deemed to be zero under:
exclusion
Harbour
Harbour
activities
The availability of a safe harbour or simplification should not be treated, by itself, as removing the Top-up Tax registration obligation.
How will the Group register?
Two registration routes, one obligation
Late registration: An administrative penalty of AED 10,000 per affected Entity may apply for submission of registration application beyond the due date.
Pillar Two Registration process
EmaraTax
Registration Route
Registration
Review
TRN Issued
What should you do now?
- Assess whether the Group meets the MNE and EUR 750 million tests.
- Map all UAE entities and Permanent Establishments and determine their QDMTT classification.
- Decide whether Entity-by-Entity or DDFE registration is appropriate.
- Prepare the required Entity, ownership and registration information.
- Register through Emara Tax within the applicable deadline.
As the due date for registration is approaching fast, it is highly recommended for MNE group in scope to act promptly. In case you require any assistance or further information, please feel free to reach out to our team.
GCC tax
