UAE FTA establishes Pillar Two registration and deregistration deadlines

The UAE Federal Tax Authority has issued Decision No. 12 of 2026, establishing registration, deregistration and scope-notification deadlines for entities affected by the UAE’s domestic minimum top-up tax.

The decision was issued on 16 July 2026 and applies to fiscal years beginning on or after 1 January 2025. Its central rule requires an entity subject to the UAE top-up tax to register no later than seven months after the end of the first fiscal year in which it falls within scope. A transitional rule gives entities whose fiscal year ended before 30 April 2026 until 30 November 2026 to register.

The decision also addresses what happens when an entity leaves an MNE group, ceases to exist or temporarily falls outside the top-up tax rules. It permits certain filings to be made through a Domestic Designated Filing Entity, but it does not eliminate the need to analyse the position of each UAE entity.

Background: the UAE domestic minimum top-up tax

The UAE top-up tax regime is contained in Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises. It applies for fiscal years beginning on or after 1 January 2025.

Broadly, the regime applies to UAE entities belonging to an MNE group whose consolidated annual revenue is at least €750 million in at least two of the four fiscal years preceding the tested fiscal year. The rules are intended to operate consistently with the OECD GloBE Model Rules and associated Commentary and Administrative Guidance. 

General registration deadline 

Article 2(1) of Decision No. 12 requires an entity subject to top-up tax to register with the FTA within a period not exceeding seven months from the end of the first fiscal year in which it falls within the scope specified in Article 1(1) of the Annex to Cabinet Decision No. 142.

The provision is framed as an initial registration obligation. Decision No. 12 does not impose an annual renewal of registration. Subsequent changes in scope are instead dealt with through the notification and deregistration rules discussed below.

Indicative applications of the ordinary rule include:

The transitional rule applies where the fiscal year ends before 30 April 2026. A fiscal year ending on 30 April itself therefore appears to remain subject to the ordinary seven-month rule. The resulting deadline is nevertheless also 30 November 2026.

Transitional registration deadline

Article 2(2) provides that an entity whose fiscal year ended before 30 April 2026 must register on or before 30 November 2026.

For an MNE group with a calendar fiscal year, the first UAE DMTT fiscal year will generally end on 31 December 2025. Because that date is before 30 April 2026, an in-scope UAE entity receives the benefit of the transitional deadline and must register by 30 November 2026.

The practical effect is:

For a calendar-year group, the transitional provision therefore extends the registration period by four months compared with the ordinary seven-month calculation.

Registration is entity-focused

Article 2 refers to an “Entity subject to Top-up Tax.” Consequently, groups should not assume that an existing UAE corporate tax registration at group or entity level automatically satisfies the separate Pillar Two registration requirement.

A registration analysis should identify:

-every UAE entity belonging to the relevant MNE group;

-each entity’s status under Cabinet Decision No. 142;

-the first fiscal year for which that entity is within scope;

-whether the transitional deadline applies; and

-whether a Domestic Designated Filing Entity will make the application on its behalf.

This analysis may need to include permanent establishments, reverse hybrid entities, joint ventures, minority-owned constituent entities and other entities receiving specific treatment under the UAE rules.

Deregistration following cessation or departure from the group