The Federal Tax Authority has quietly reshaped the UAE Corporate Tax Return shareholding disclosure requirement, and it catches many businesses off guard. On the EmaraTax portal, the Corporate Tax Return now asks for far more than a simple yes-or-no confirmation of Multinational Enterprise (MNE) Group membership. Taxable persons must now name their immediate and ultimate parent companies, confirm their countries of tax residency, and, where available, provide tax identification numbers. If your business has any form of group or holding structure, this update directly affects your next corporate tax filing.
This guide explains what has changed, who it applies to, why the FTA introduced it, and the practical steps your business should take before filing.
What Is the FTA Shareholding Disclosure Requirement?
Previously, the UAE Corporate Tax Return only required a taxable person to confirm whether it belonged to an MNE Group. The FTA has now expanded this section to capture detailed ownership information, bringing the return closer in line with international tax transparency standards used by the OECD.
Depending on your ownership structure, you may now need to disclose:
- The name of the MNE Group (as per the consolidated financial statements of the Ultimate Parent Company)
- The name of the Ultimate Parent Company
- The country of tax residency of the Ultimate Parent Company
- The Tax Identification Number (TIN) or Tax Registration Number of the Ultimate Parent Company
- The name of the Immediate Parent Company
- The country of tax residency of the Immediate Parent Company
- The Tax Identification Number (TIN) or Tax Registration Number of the Immediate Parent Company
Some fields are mandatory, others are optional where applicable. The table below sets out the current disclosure status.
Who Needs to Comply with the New Shareholding Disclosure Requirement?
Not every business will need to complete every field, but every taxable person should review the requirement before submitting a return. The disclosure is most relevant if your business:
- Is a member of a Multinational Enterprise (MNE) Group
- Has an identifiable immediate parent company or ultimate parent company
- Operates as a subsidiary of another UAE or foreign entity
- Forms part of a wider UAE or international corporate group
Businesses that are owned directly by individuals, with no corporate parent or group structure, are likely to have limited or no disclosure obligations under this section. However, the FTA has not clarified how these fields should be handled where a taxable person is individually owned, so a cautious, well-documented approach is advisable rather than leaving fields blank without review.
Why This Update Matters: The Pillar Two Connection
On the surface, the new fields look purely administrative. In practice, the terminology “MNE Group,” “ultimate parent,” and “immediate parent,” is drawn directly from the OECD’s GloBE framework that underpins the UAE’s Domestic Minimum Top-up Tax (DMTT), effective for financial years starting on or after 1 January 2025 under Cabinet Decision No. 142 of 2024.
The DMTT applies to constituent entities of MNE Groups with consolidated group revenue of EUR 750 million or more in at least two of the four preceding financial years. The Pillar Two Top-up Tax registration process on EmaraTax already asks for this same ownership data. By adding equivalent fields to the Corporate Tax Return, the FTA is aligning its datasets so that Corporate Tax filings, Pillar Two registrations, Country-by-Country Reporting (CbCR) notifications, and transfer pricing documentation can be cross-checked against one another.
For businesses within scope of the DMTT, this means the ownership details entered in the Corporate Tax Return should match, exactly, the information used for Pillar Two registration and transfer pricing filings. Inconsistent group data across these workstreams is likely to attract FTA queries.
Risks of Getting It Wrong
Treating the shareholding disclosure as a minor administrative field is a mistake. Common risks include:
- Filing delays caused by incomplete or inconsistent parent company details
- FTA clarification requests or information notices
- Mismatches between the Corporate Tax Return, Pillar Two/DMTT registration, and transfer pricing documentation
- Increased scrutiny of related party transactions and group structuring
- Administrative penalties for inaccurate disclosures under UAE Corporate Tax regulations
Because the fields for Ultimate Parent and Immediate Parent are mandatory where applicable, businesses that leave this until the filing deadline risk a last-minute scramble to trace ownership records, particularly where the structure involves holding companies, trusts, funds, or dual-listed groups.
How to Prepare Before Filing Your Corporate Tax Return
A structured approach now will save time and reduce compliance risk later. Before you access the Corporate Tax Return section on EmaraTax, your business should:
- Map your full ownership and shareholding structure, including any intermediate holding entities
- Identify the Immediate Parent Company and the Ultimate Parent Company using consolidation principles consistent with GloBE definitions
- Confirm the country of tax residency for each parent entity
- Gather the Tax Identification Number (TIN) or Tax Registration Number for each parent, where available
- Cross-check this data against your CbCR notifications, Pillar Two/DMTT registration records, and transfer pricing documentation
- Assess whether your group meets the EUR 750 million DMTT threshold and, if so, progress Pillar Two registration without waiting for further deadline announcements
- Review every field for accuracy and consistency before final submission
If your business already filed its Corporate Tax Return before this update, it is worth documenting your group structure data now, so you can respond promptly to any future FTA request, amendment, or registration requirement.
Frequently Asked Questions
What is the UAE FTA’s new shareholding disclosure requirement?
It is an expanded section of the UAE Corporate Tax Return requiring certain taxable persons to disclose their MNE Group name, Ultimate Parent Company, Immediate Parent Company, their countries of tax residency, and tax identification numbers where applicable.
Does every UAE company need to complete the shareholding disclosure fields?
No. The requirement mainly applies to businesses that are part of an MNE Group, have a corporate parent, or operate as a subsidiary. Businesses owned directly by individuals, with no group structure, generally have limited obligations, though the fields should still be reviewed.
How does the shareholding disclosure relate to Pillar Two and the DMTT?
The terminology and data fields mirror the information required for Domestic Minimum Top-up Tax (DMTT) registration under the OECD’s GloBE framework. Businesses within the scope of the EUR 750 million DMTT threshold should ensure their Corporate Tax Return and Pillar Two registration data are consistent.
How Tax Gian Can Help
Tax Gian, part of Jitendra Tax Consultants, has supported UAE businesses through more than 25 years of regulatory change. Our team of tax consultants helps businesses of every size manage the new shareholding disclosure requirement accurately and on time.
We assist with:
- Reviewing your ownership and group structure to determine which disclosures apply
- Identifying and verifying Immediate and Ultimate Parent Company details
- Preparing and filing your Corporate Tax Return through the EmaraTax portal
- Reconciling group data across Corporate Tax, [transfer pricing and Pillar Two/DMTT filings
- Ongoing corporate tax advisory and FTA representation
If you are unsure whether the new shareholding disclosure requirement applies to your business, do not leave it to guesswork. Schedule a free consultation with Tax Gian to have our team review your structure before your filing deadline.
