UAE Pillar Two Top-up Tax: Registration, Deregistration and Notification Timeline

The Federal Tax Authority (FTA) has issued Decision No. 12 of 2026 prescribing registration, deregistration, and notification requirements, together with the applicable compliance timelines, for entities within the scope of the UAE Domestic Minimum Top-Up Tax (DMTT) regime introduced under Cabinet Decision No. 142 of 2024.

The Decision provides much-needed clarity on the procedural compliance obligations for in-scope entities and outlines the timelines for fulfilling their registration, deregistration, and notification requirements under the UAE DMTT regime.

Outlined below is a summary of the key compliance requirements and the corresponding timelines, prescribed by the FTA for entities within the scope of the UAE DMTT regime.

1. DMTT Registration – Compliance Timeline

Category of Entity Timeline for Submission of Tax Registration Application
Entities with a Fiscal Year ending before 30 April 2026 On or before 30 November 2026
All other entities within the scope of UAE DMTT Within seven (7) months from the end of the first Fiscal Year in which they are subject to the UAE DMTT regime

2. DMTT Deregistration – Compliance Timeline

Category of Entity Timeline for Submission of Tax Registration Application
Entity ceases to exist or ceases to be in scope of UAE DMTT regime Within six (6) months from the earliest of the following dates:

  1. the date on which the entity ceases to exist; or
  2. the end of the Fiscal Year in which the entity leaves an MNE Group and that Entity is no longer in scope of UAE DMTT regime
Entity ceasing to exist before 30 June 2026 On or before 31 December 2026

Further, an entity will not be eligible for deregistration unless it has fully settled all outstanding Top-up Tax liabilities and applicable penalties and filed all Top-up Tax Returns and Pillar Two Information Returns required under Cabinet Decision No. 142 of 2024.

3. In-Scope and Out-of-Scope Notification Timeline

Requirement Timeline
Out-of-scope notification An entity that is a member of an MNE Group must submit an out of-scope notification to FTA within six (6) months from the end of the tested Fiscal Year where the MNE Group ceases to be within the scope of UAE DMTT regime.
Validity of out-of-scope notification Once submitted, an ‘Out-of-scope notification’ remains valid for the tested fiscal year and the subsequent four (4) consecutive fiscal years, unless the entity subsequently becomes in scope to the UAE DMTT regime, in which case it is required to file an in-scope notification within seven (7) months from the end of the relevant tested fiscal year with the FTA.
Tax deregistration requirement Where an out-of-scope notification remains valid for five (5) consecutive fiscal years, the entity must submit a Tax Deregistration application to the FTA within six months from the end of the fifth consecutive fiscal year in which it remained out of scope, unless an in-scope notification becomes applicable during that period.

An appointed Domestic Designated Filing Entity may fulfil the Top-Up Tax compliance obligations on behalf of eligible group entities by submitting the required registration, deregistration and notifications to the FTA.

Entities falling within the scope of the UAE DMTT regime should prioritize completing their registration process with the FTA at the earliest to ensure timely compliance with the applicable Pillar Two requirements.

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