UAE DMTT (Pillar Two) Compliance — from scope assessment to registration, impact assessment and filing
UAE entities of multinational groups with consolidated revenue of EUR 750 million or more are subject to the Domestic Minimum Top-up Tax (DMTT) for fiscal years beginning on or after 1 January 2025, securing a 15% minimum effective tax rate. DMTT registration is separate from Corporate Tax registration. Biz Easy supports group scope assessment, FTA registration, GloBE effective tax rate impact assessment and Pillar Two information return design, coordinating with your group tax function throughout.
Entities whose first in-scope fiscal year ended before 30 April 2026 must submit their Top-up Tax registration application by 30 November 2026 (FTA Decision No. 12 of 2026, Article 2(2)). For calendar-year groups, and for March year-end groups whose first in-scope year ran April 2025 to March 2026, this transitional deadline applies.
Pillar Two has changed the assumption that the UAE is a low-tax jurisdiction
The UAE introduced Corporate Tax at a 9% headline rate in June 2023 and applies a Domestic Minimum Top-up Tax under OECD BEPS 2.0 (Pillar Two) for fiscal years beginning on or after 1 January 2025. Where the effective tax rate of UAE entities falls below 15%, the difference is collected in the UAE. With Income Inclusion Rules in force in many parent jurisdictions, whether low-taxed UAE profits are settled under the UAE DMTT or topped up at parent level is a question of group tax cost and governance.
Registration, notification and filing obligations at a glance
Based on the FTA Top-up Tax Guide on Scope and Registration (TTGREG1, August 2026), these are the points that most often lead to missed registrations.
Who must register
- UAE-located Constituent Entities (subsidiaries, branches, permanent establishments and joint ventures) must register for Top-up Tax separately from Corporate Tax. A Corporate Tax Tax Group registration does not carry over
- A UAE branch (permanent establishment) of a foreign company must register
- Entities expecting zero Top-up Tax must still register, including where the de minimis exclusion, the Transitional CbCR Safe Harbour, the Simplified Calculations Safe Harbour or the initial-phase relief applies
- Only Excluded Entities (governmental entities, international organisations, non-profits, pension funds and similar), UAE Investment Entities and stateless permanent establishments are outside the registration requirement
Scope test (consolidated revenue threshold)
- The group is in scope where annual revenue in the Ultimate Parent Entity's consolidated financial statements is EUR 750 million or more in at least two of the four fiscal years immediately preceding the tested year. The tested year itself is not counted
- The threshold is pro-rated for fiscal years shorter than twelve months (EUR 562.5 million for a nine-month year)
- Consolidated statements in a currency other than EUR are converted using the average of the daily reference rates for December preceding the fiscal year (ECB or Central Bank of the UAE)
- A UAE entity acquired by an in-scope group must register within seven months of the end of the fiscal year in which it joined
How and when to register
| Item | Detail | Reference (TTGREG1) |
|---|---|---|
| Where | EmaraTax portal. Entities already registered with the FTA for any tax use the same Taxable Person (same TIN); entities with no FTA registration create a TIN first | Section 9.1 |
| Group registration (DDFE) | A Domestic Designated Filing Entity may register, file and pay on behalf of the domestic group. Each represented entity authorises the DDFE on EmaraTax or by a signed authorisation letter uploaded with the application | Sections 8.1, 9.3 |
| Documents | (1) evidence of the name and TIN of the UPE where located outside the UAE; (2) evidence of the name and TIN of the Designated Filing Entity, if any, where located outside the UAE; (3) an overview of the MNE group structure | Section 9.3 |
| Tax Agents | A Tax Agent appointed for Top-up Tax must be listed with the FTA as a Tax Agent for Corporate Tax | Section 9.4 |
| Deadline | Fiscal year ending before 30 April 2026: 30 November 2026. Otherwise: within seven months of the end of the first in-scope fiscal year | Section 8.4 (FTA Decision 12/2026, Art. 2) |
| If not registered | The FTA may register the entity on the information available to it, effective from the original registration date | Section 8.4 |
Pillar Two Information Return
- The entity that will file the Pillar Two Information Return (GIR) is notified to the FTA at the time of registration
- Under Ministerial Decision No. 133 of 2026 there are four routes: (1) each UAE Constituent Entity files; (2) a Designated Local Entity files a single return for all UAE entities; (3) the UPE files in a jurisdiction with a Qualifying Competent Authority Agreement with the UAE; (4) a Designated Filing Entity files in such a jurisdiction. Routes 2 to 4 discharge the UAE entities' individual filing obligation
- A Designated Local Entity (information return only) and a DDFE (registration, return and payment) are distinct roles; one entity may hold both, or the roles may be split
This page summarises the regime. Specific deadlines and procedures depend on your fiscal year and group structure; please contact us.
Sources: FTA Top-up Tax Guide | Scope and Registration (TTGREG1, August 2026); Cabinet Decision No. 142 of 2024; FTA Decision No. 12 of 2026; Ministerial Decision No. 133 of 2026. Content as at 13 October 2026.
Four service areas, available separately or end to end
Engage us for scope assessment and registration only, for the impact assessment only, or for the full compliance cycle.
Scope Assessment & Registration
Consolidated revenue threshold testing (two of four years, short-year pro-rating, EUR conversion), Excluded and Investment Entity review, mapping of the domestic group including UAE branches, DDFE selection and authorisation letters, preparation of supporting documents (UPE TIN evidence, group structure chart), EmaraTax registration and responses to FTA information requests, completed ahead of the 30 November 2026 deadline.
DMTT Impact Assessment (Pillar Two)
Over approximately four weeks we deliver a report (English, around ten pages) covering group scope, the UAE regimes applicable to your entities (QFZP, exempt income), a GloBE effective tax rate estimate for each UAE entity, and a risk rating with response options. We reconcile IFRS and Corporate Tax differences, deferred tax and intra-group adjustments and classify the risk of falling below 15% as High, Medium or Low, in a form suitable for board and group tax reporting.
Information Return & Top-up Tax Return
Preparation and filing of the Pillar Two Information Return and the Top-up Tax Return, and FTA correspondence, aligned with the group's own Pillar Two filings to avoid duplication or gaps.
Ongoing Compliance & Regulatory Updates
Management of out-of-scope and in-scope notifications and deregistration, and review of positions as FTA guidance and OECD administrative guidance evolve, operated together with Corporate Tax filing, QFZP assessment and transfer pricing documentation.
Our approach
Initial consultation and scoping (free)
We review group structure, consolidated revenue and the activities and tax status of your UAE entities to identify whether DMTT applies and what is required.
Scope assessment and DDFE selection
We document the scope test from consolidated financial statements and the group chart, and agree the registering entity.
FTA registration
We submit the EmaraTax application on your behalf and handle FTA queries.
Impact assessment (optional)
We deliver the GloBE ETR estimate and response strategy report.
Filing and ongoing compliance
We support information and tax returns, the annual scope test and regulatory change.
Why companies choose Biz Easy
UAE tax and group tax governance together
Our team, including chartered accountants, structures responses around the interaction between the UAE DMTT and the parent jurisdiction's Income Inclusion Rule.
Track record
We have delivered DMTT impact assessments for UAE entities of international groups, including the reporting format used to brief group management.
Integrated with Corporate Tax, QFZP and transfer pricing
DMTT does not stand alone. The same team handles Corporate Tax returns, QFZP eligibility and transfer pricing documentation.
Tracking regulatory change
We monitor FTA decisions and guides and share implications with clients before deadlines.
Frequently asked questions
Is our group in scope?
UAE subsidiaries, branches and permanent establishments are in scope where revenue in the UPE's consolidated financial statements is EUR 750 million or more in at least two of the four fiscal years preceding the tested year, for fiscal years beginning on or after 1 January 2025. Currency conversion and Excluded Entity classification affect the test; we confirm this in the initial consultation.
We are already registered for Corporate Tax. Do we need a separate DMTT registration?
Yes. Top-up Tax registration is a separate application under FTA Decision No. 12 of 2026, and a Corporate Tax Tax Group registration does not carry over.
Our group has a December year end. When is the deadline?
Your first in-scope fiscal year ended on 31 December 2025, before 30 April 2026, so the transitional deadline of 30 November 2026 applies under Article 2(2) of FTA Decision No. 12 of 2026.
We have several UAE entities. Does each one register?
Each entity may register individually, or a Domestic Designated Filing Entity may register on behalf of the domestic group with each entity's authorisation on EmaraTax or by signed letter. Each entity receives a Pillar Two Top-up Tax TRN; the DDFE also receives a group TRN.
We only have a branch in the UAE. Must it register?
Yes. A UAE branch (permanent establishment) of a foreign company is a Constituent Entity of the group and must register.
We expect zero Top-up Tax under a safe harbour. Must we still register?
Yes. Entities covered by the de minimis exclusion, the Transitional CbCR Safe Harbour, the Simplified Calculations Safe Harbour or the initial-phase relief remain within the charging provision and must register.
Our free zone entity is taxed at 0% as a QFZP. Will it be taxed at 15% under DMTT?
QFZP status does not exempt an entity from DMTT. Where the UAE effective tax rate is below 15%, the difference is collected as Top-up Tax, subject to the Substance-based Income Exclusion, the de minimis exclusion and other adjustments, so the actual impact requires calculation.
What happens if we miss the registration deadline?
An administrative penalty of AED 10,000 applies. Where a DDFE registers on behalf of the group, the penalty applies per entity for which the application was not submitted.
Is anything required at parent-company level?
Where the parent jurisdiction applies an Income Inclusion Rule, Top-up Tax paid in the UAE is recognised because the UAE DMTT holds transitional qualified status. Alignment with the group's Pillar Two and information return filings remains necessary, and we coordinate with your group tax function.
Related resources
Start by confirming whether your group is in scope
Whether you are unsure about the revenue threshold or which entity should register, the initial consultation is free of charge.
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