Multinational groups operating in the UAE now have a firm answer to a question that has lingered since Pillar Two registration opened on EmaraTax: when, exactly, must an in-scope entity register for Top-up Tax? Federal Tax Authority Decision No. 12 of 2026, issued on 16 July 2026, sets out binding registration, deregistration, and scope-notification timelines for the Domestic Minimum Top-up Tax (DMTT) introduced under Cabinet Decision No. 142 of 2024.
If your group has a UAE presence and consolidated global revenue at or above EUR 750 million, this Decision affects your compliance calendar directly, and missing a deadline exposes the entity to unnecessary penalty risk.
This guide breaks down the registration and deregistration deadlines in plain terms, explains the scope-notification mechanism, and sets out what group finance and tax teams should action now.
What FTA Decision No. 12 of 2026 Covers
FTA Decision No. 12 of 2026 supplements Cabinet Decision No. 142 of 2024 (the DMTT law) and Federal Decree-Law No. 47 of 2022 (UAE Corporate Tax). It applies to Fiscal Years starting on or after 1 January 2025, meaning groups with an in-scope first Fiscal Year already underway are already inside its timelines.
The Decision addresses four practical compliance actions:
- Tax Registration of entities that fall in scope of Top-up Tax
- Tax Deregistration of entities that leave scope or cease to exist
- In-scope and out-of-scope notifications for entities whose group status changes year to year
- Registration and deregistration handled centrally by a Domestic Designated Filing Entity on behalf of a group
Who Must Register for UAE Top-Up Tax
An entity is in scope where it is a Constituent Entity of an MNE Group whose consolidated annual revenue meets the EUR 750 million Pillar Two threshold for at least two of the four preceding Fiscal Years, as determined under Article 1.1 of the annexure to Cabinet Decision No. 142 of 2024. Scope is assessed at group level, not on the UAE entity’s standalone turnover, so a UAE subsidiary, branch, or joint venture can fall within DMTT even where its local revenue is modest.
UAE Top-Up Tax Registration Deadlines
Article 2 of the Decision sets two registration deadlines, depending on when the entity’s first in-scope Fiscal Year ends.
Standard rule
An in-scope entity must submit a Tax Registration application within seven months from the end of its first Fiscal Year in scope.
Transitional rule for early Fiscal Years
Where the entity’s Fiscal Year ends before 30 April 2026, the standard seven-month window is overridden. The Tax Registration application is instead due on or before 30 November 2026, regardless of the actual Fiscal Year end date.
In practice, this transitional deadline captures most calendar-year groups with a 2025 Fiscal Year, since a Fiscal Year ending 31 December 2025 would otherwise fall due later than 30 November 2026 under the seven-month rule. Groups should confirm which rule applies to their specific Fiscal Year end rather than assuming the standard seven-month period applies by default.
UAE Top-Up Tax Deregistration Deadlines
Article 3 mirrors the registration structure for entities exiting Top-up Tax scope.
Standard rule
A Tax Deregistration application is due within six months from the earliest of:
- the date the entity ceases to exist, or
- the end of the Fiscal Year in which the entity leaves an MNE Group and no longer falls in scope under Article 1.1
Transitional rule
Where the entity ceased to exist before 30 June 2026, the deregistration application is due on or before 31 December 2026.
Deregistration is conditional, not automatic. An entity cannot be deregistered until it has:
- settled all Top-up Tax and penalties payable in full, and
- filed all outstanding Top-up Tax Returns and Pillar Two Information Returns due under Cabinet Decision No. 142 of 2024
Where an entity meets the deregistration conditions but fails to apply, the FTA retains discretion to deregister it based on the information available. This does not remove the underlying obligation to settle liabilities and file returns; it simply means the FTA can act administratively where a group has not.
In-Scope and Out-of-Scope Notifications
Article 4 introduces a notification mechanism for entities whose group crosses in and out of the EUR 750 million threshold over time, distinct from full registration and deregistration.
- Out-of-scope notification: where an entity’s MNE Group falls out of scope for a tested Fiscal Year, the entity must notify the FTA within six months from the end of that Fiscal Year.
- Validity period: an out-of-scope notification remains valid for the tested Fiscal Year plus the following four consecutive Fiscal Years, unless the group re-enters scope sooner.
- In-scope notification: if the group re-enters scope during that validity window, the entity must submit an in-scope notification within seven months from the end of the relevant tested Fiscal Year.
- Automatic deregistration trigger: where an out-of-scope notification remains valid for five consecutive Fiscal Years without the group re-entering scope, the entity must submit a full Tax Deregistration application within six months from the end of that fifth Fiscal Year.
This structure gives groups near the EUR 750 million threshold a defined runway rather than requiring immediate deregistration the moment revenue dips, while still closing the loop after five years of sustained out-of-scope status.
Domestic Designated Filing Entities
Article 5 confirms that, where a Domestic Designated Filing Entity has been appointed under Article 2.2 of the annexure to Cabinet Decision No. 142 of 2024, that entity submits the Tax Registration, Tax Deregistration, and in-scope or out-of-scope notifications on behalf of all members of:
- a Domestic Main Group, a Domestic Minority-owned Subgroup, or a Reverse Hybrid Entity, or
- a Domestic JV Group
This centralises compliance for group structures with multiple UAE Constituent Entities, avoiding duplicate filings across entities that share a common UAE footprint.
Why the Deadlines Matter for Your Group
Top-up Tax sits outside the standard UAE Corporate Tax return and is administered through a separate EmaraTax track. Groups that have already completed standard Corporate Tax registration sometimes assume Pillar Two compliance is automatically covered; it is not. A missed Top-up Tax registration or deregistration deadline is a distinct compliance failure, assessed under the DMTT and Corporate Tax penalty framework, and it sits alongside, not instead of, the group’s ongoing obligation to file Top-up Tax Returns and Pillar Two Information Returns.
Groups should treat the following as immediate priorities:
- Confirm whether the group meets the EUR 750 million consolidated revenue threshold across the required testing period
- Map every UAE Constituent Entity, including branches, joint ventures, and minority-owned subgroups
- Identify the correct registration deadline for each entity’s Fiscal Year end, distinguishing the standard seven-month rule from the 30 November 2026 transitional deadline
- Decide whether to appoint a Domestic Designated Filing Entity to consolidate filings across the UAE structure
- Build a rolling calendar for scope-notification deadlines where group revenue sits close to the threshold
Frequently Asked Questions
What is the deadline to register for UAE Top-Up Tax in 2026?
The standard deadline is seven months from the end of the entity’s first in-scope Fiscal Year. Entities with a Fiscal Year ending before 30 April 2026 must register by 30 November 2026 instead, under the transitional rule in Article 2 of FTA Decision No. 12 of 2026.
Does Top-up Tax deregistration happen automatically when a group falls below the threshold?
No. Deregistration requires a formal application within six months of the entity ceasing to exist or leaving scope, and only once all Top-up Tax liabilities are settled and returns filed. Below the automatic five-year out-of-scope trigger, entities instead file scope notifications rather than deregistering.
Can one entity file for the whole UAE group?
Yes, where a Domestic Designated Filing Entity has been appointed, it can submit registration, deregistration, and scope notifications on behalf of all members of a Domestic Main Group, Domestic Minority-owned Subgroup, Reverse Hybrid Entity, or Domestic JV Group.
Does this Decision change the DMTT rate or scope test itself?
No. FTA Decision No. 12 of 2026 sets administrative registration, deregistration, and notification timelines. The underlying 15% Domestic Minimum Top-up Tax and the EUR 750 million scope test remain governed by Cabinet Decision No. 142 of 2024.
Get Your Group’s Top-Up Tax Compliance Calendar in Order
Registration and deregistration deadlines under FTA Decision No. 12 of 2026 are entity-specific and depend on your group’s Fiscal Year end, scope history, and filing structure. Getting the date wrong, or missing the distinction between the standard and transitional rules, creates avoidable exposure for an otherwise compliant group.
Tax Gian advises multinational groups on UAE Domestic Minimum Top-up Tax registration, deregistration, and Pillar Two Information Return compliance, including Domestic Designated Filing Entity structuring for groups with multiple UAE Constituent Entities. Get in touch with our tax advisory team today to confirm your entity’s exact registration or deregistration deadline and put a compliant filing calendar in place before it becomes a penalty risk.
