UAE DMTT: When Must Your Group Register for Top-Up Tax?

Created By : Yeeshu Sehgal | UAE Tax Lead

A UAE company inside a large multinational group closed its first in-scope Fiscal Year on 31 December 2025. Registration is not due until 30 November 2026 - but the runway is short: the group must first know which UAE entities are caught, how each is owned, and who will answer for the numbers. FTA Decision No. 12 of 2026 has fixed the dates; being ready for them is the work that starts today.

Who the regime catches

Cabinet Decision No. 142 of 2024 introduced the UAE Top-Up Tax for Fiscal Years from 1 January 2025 - the UAE's leg of OECD Pillar Two. It catches UAE Constituent Entities of groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding Fiscal Years. Decision No. 12 of 2026 sets the compliance dates.

The registration clock

An in-scope entity registers via EmaraTax within seven months of its first in-scope Fiscal Year-end. Transitional relief: where that year ends before 30 April 2026, registration is due by 30 November 2026 - the first real Pillar Two milestone for most UAE groups.

Registration deadlines at a glance

Registration deadline by first in-scope Fiscal Year-end:

Transitional relief fixes 30 November 2026 for year-ends before 30 April 2026. Map each date to the group's actual Fiscal Year.

Register separately, or appoint a Domestic Designated Filing Entity?

Each UAE member can register in its own name, or the group can appoint a Domestic Designated Filing Entity to handle registrations, deregistrations and notifications centrally - for a Domestic Main Group, Minority-Owned Subgroup, Reverse Hybrid Entity or Domestic JV Group. Centralising cuts duplication but concentrates responsibility, and needs proper authorisation. The choice turns on entity count, ownership and how the group runs compliance.

Deregistration and out-of-scope notifications

Deregistration is due within six months of a cessation or exit event (transitional: 31 December 2026 for entities that ceased before 30 June 2026). An out-of-scope notification is due within six months of the tested Fiscal Year-end and holds for that year plus the next four. Re-entry triggers an in-scope notification within seven months.

The work that comes before the form

Registration is the visible deadline; the real work sits behind it:

• Map UAE entities, PEs, JVs and special categories in scope;
• Choose, per entity, separate registration or a DDFE;
• Reconcile the UAE position with the group's global Pillar Two analysis;
• Assign ownership of data, filing, payment and notifications; and
• Track restructurings and membership changes for future notifications.

Start with the operating model, not the deadline - entity mapping, ownership and accountability turn November into a formality.

How we can help

AKM Global can map your UAE entities against the Top-Up Tax rules, model the separate-registration versus Domestic Designated Filing Entity decision, align the UAE and global Pillar Two positions, and put the governance and notification calendar in place through registration and beyond.