New Top-Up Tax rules have been introduced in the UAE: Do they affect your business?
The UAE Top-Up Tax registration is now available on the Federal Tax Authority (FTA)’s EmaraTax portal. This is a key milestone in the country’s implementation of the OECD’s 15% Global Minimum Tax under Pillar Two. This update confirms that large multinational groups operating in the UAE must prepare for registration, compliance assessments, reporting obligations, and penalty-risk management.
As global tax reforms accelerate, the UAE’s introduction of the Domestic Minimum Top-Up Tax (DMTT) is consistent with international standards and strengthens transparency in multinational structures. The EmaraTax Top-Up Tax registration function is a clear call-to-action for CFOs and tax directors to complete the required assessment and registration process within the FTA timeline.
This article explains the Top-Up Tax rule, who is impacted, the confirmed registration deadline, and what steps should be taken in this regard.
What Is the UAE Top-Up Tax?
The UAE Top-Up Tax is a component of the OECD’s Pillar Two framework, which seeks to establish a minimum effective tax rate of 15% for large multinational enterprise (MNE) groups in each jurisdiction they operate in.
The Domestic Minimum Top-Up Tax is part of UAE Cabinet Decision No. 142 of 2024, and applies when the effective tax rate of an in-scope MNE group in the UAE is below 15%, which then results in a “top-up” to meet the global minimum.
This is fully in line with the OECD Global Anti-Base Erosion (GloBE) Model Rules and the administrative guidance adopted by the UAE Ministry of Finance. At this stage, the UAE has implemented the DMTT but has not introduced the Income Inclusion Rule.
Who Is Impacted? Understanding the EUR 750 Million Threshold
The Top-Up Tax only applies to large multinational groups, meaning that normal standalone small and medium-sized enterprises (SMEs) are not affected.
A group must meet the following criteria to be in-scope:
- Annual consolidated global revenue of at least EUR 750 million in two of the last four fiscal years.
- Must be part of an MNE group with entities or permanent establishments in more than one jurisdiction.
- The group has one or more UAE Constituent Entities, UAE permanent establishments, UAE joint ventures, or other UAE entities within the scope of the UAE DMTT rules.
This threshold is in line with the OECD Pillar Two rules and has been reiterated in announcements and guidance published by the UAE tax authorities.
If the relevant group does not exceed the EUR 750 million consolidated revenue threshold, the UAE Top-Up Tax will not apply.
Entities not required to register may include Excluded Entities, UAE Investment Entities, stateless Permanent Establishments, stateless Tax Transparent Entities, and certain stateless dual-located entities outside the charging rule. However, this requires a separate assessment. An Exempt Person under UAE Corporate Tax is not automatically an Excluded Entity for Top-Up Tax purposes.
Why the EmaraTax Top-Up Tax Portal Matters Now
Now that the Top-Up Tax registration is live on EmaraTax, in-scope MNEs should begin preparations for compliance. This includes:
- Registration of all UAE constituent entities
- Measuring effective tax rates
- GloBE Information Return preparation
- Data preparation for reporting cycles
- Reviewing the registration deadline and late registration penalty exposure
The GloBE Information Return follows the OECD’s standardized template, adopted in the UAE under Ministerial Decision No. 88 of 2025.
The DMTT applies from 1 January 2025 for financial years starting on or after that date, so the first compliance cycle has already started.
The FTA has now confirmed the Top-Up Tax registration timeline. For Fiscal Years ending before 30 April 2026, registration must be completed by 30 November 2026. In other cases, registration must be completed within 7 months from the end of the first Fiscal Year in which the entity is in scope.
A late registration penalty of AED 10,000 may apply. Where a Domestic Designated Filing Entity fails to register multiple represented entities on time, the penalty can apply for each entity not registered within the required timeline.
The filing timeline is also confirmed: in-scope entities must submit their Top-Up Tax Return within 15 months of the end of the relevant tax period, or 18 months for the transitional first year. This means a group with a 31 December 2025 year-end has its first return due by 30 June 2027. A transitional penalty relief applies for late filing of the Top-Up Tax Return or the GloBE Information Return for fiscal periods beginning on or before 31 December 2026, provided the group has taken reasonable measures to apply the rules correctly. This relief does not remove the obligation to register on time.
Top-Up Tax registration is separate from UAE Corporate Tax registration. Having a Corporate Tax registration or TRN does not remove the requirement to complete Top-Up Tax registration where the entity is in scope. Where the entity is already registered with the FTA, the Top-Up Tax TRN should use the same TIN or first 10 digits.
Next Steps for In-Scope Multinational Groups
This is a step-by-step guide for CFOs and tax leaders to prepare for UAE Top-Up Tax compliance.
1. Pillar Two Applicability Check
Find out if your group has consolidated revenue above the EUR 750 million threshold in two out of the last four financial years.
2. Evaluate Effective Tax Rate of UAE
Identify the jurisdictional effective tax rate, and then estimate possible top-up exposure under the 15% minimum.
3. Identify UAE Constituent Entities
Identify all UAE entities, permanent establishments, joint ventures, and other entities that fall within the GloBE and UAE DMTT definitions.
4. Collect Required Financial Information
Gather consolidated financial statements, entity-level information, and GloBE-specific disclosures needed for compliance.
5. Register on EmaraTax
Decide at group level whether to appoint a Domestic Designated Filing Entity (DDFE) to register and file on behalf of all UAE group members, or have each entity register individually. Complete the UAE Top-Up Tax registration for all in-scope entities via EmaraTax within the confirmed FTA timeline: 30 November 2026 for Fiscal Years ending before 30 April 2026, or within 7 months from the end of the first in-scope Fiscal Year in other cases.
Safe harbours or rules that reduce the Top-Up Tax amount to zero do not automatically remove the registration requirement if the entity remains within the UAE DMTT charging provisions.
6. Create a Compliance Framework
Establish internal processes for reporting, documentation, registration monitoring, Top-Up Tax Return filing, GloBE Information Return filing, and ongoing monitoring of Pillar Two obligations.
Act Now for Full Compliance
The launch of the UAE Top-Up Tax registration on EmaraTax is a significant milestone for multinational groups operating within the UAE. With the 15% UAE global minimum tax now in effect, and the registration deadline confirmed, CFOs and tax leaders need to take immediate steps to assess exposure, prepare data, complete registration, and avoid late registration penalties.
Corporate Tax UAE expert team helps MNEs with:
- Impact assessments of Pillar Two
- DMTT modeling and ETR calculations
- FTA registration
- Top-Up Tax registration deadline and penalty-risk review
- Reporting readiness and compliance frameworks
- Global Minimum Tax requirements of the UAE
Contact us to assess your UAE DMTT exposure, confirm registration requirements, and prepare your group for the first Top-Up Tax compliance cycle.
