UAE Issues Registration Rules for Pillar Two Top-Up Tax: What FTA Decision No. 12 of 2026 Means for Multinational Groups

The UAE Federal Tax Authority has published Decision No. 12 of 2026, setting out how in-scope multinational entities must register and deregister for the country’s Top-Up Tax under Cabinet Decision No. 142 of 2024 (the UAE’s Pillar Two Domestic Minimum Top-up Tax framework). The Decision was issued on 16 July 2026 and applies retroactively to fiscal years beginning on or after 1 January 2025. Below is a practical summary of what the Decision covers and the deadlines groups should be tracking.

Who Needs to Register

Any UAE entity that falls within scope of the Top-Up Tax rules must submit a Tax Registration application to the FTA. The standard deadline is seven months from the end of the first fiscal year in which the entity becomes in-scope. There’s an important transitional rule: entities whose first in-scope fiscal year ends before 30 April 2026 don’t follow the standard seven-month clock instead, they must register by a fixed date of 30 November 2026, regardless of their actual year-end.

Deregistration

Entities that stop being in scope — whether because they cease to exist or because they leave a Multinational Enterprise (MNE) Group and no longer meet the scope criteria, must submit a deregistration application within six months of the earlier of those two triggers. A similar transitional carve-out applies here too: if an entity ceases to exist before 30 June 2026, the deregistration deadline is fixed at 31 December 2026.

Deregistration isn’t automatic on approval. The FTA will only approve it once the entity has:

• Settled all Top-Up Tax and penalties owed in full, and
• Filed all outstanding Top-Up Tax Returns and Pillar Two Information Returns.

Once approved, the registration technically stays valid until the earliest of: the entity’s cessation date, the end of the fiscal year it left the MNE Group, or another date set by the FTA. If an entity meets the deregistration conditions but never files, the FTA has discretion to deregister it anyway based on the information it holds.

In-Scope / Out-of-Scope Notifications

Groups that fall in and out of scope over time also have notification obligations:

• If an MNE Group falls out of scope for a tested fiscal year, its UAE entities must notify the FTA within six months of that year-end.
• An out-of-scope notification is treated as valid for the tested year plus the following four fiscal years (five years total).
• If the group comes back in scope during that window, it must file an in-scope notification within seven months of the relevant year-end.
• If a group stays out of scope for all five consecutive years, the entity must then apply for deregistration within six months of the end of that fifth year — unless an in-scope notification becomes necessary first.

Filing Through a Domestic Designated Filing Entity

Where a group has appointed a Domestic Designated Filing Entity, that entity can handle registration, deregistration, and in-scope/out-of-scope notifications centrally on behalf of the whole group, covering a Domestic Main Group, a Domestic Minority-Owned Subgroup, a Reverse Hybrid Entity, or a Domestic JV Group. This avoids the need for every group member to file separately.

Key Dates at a Glance

Why This Matters Now

Because the Decision applies to fiscal years starting on or after 1 January 2025, many groups with a 2025 calendar-year fiscal year are already inside the registration clock, and those with earlier year-ends may be caught by the fixed 30 November 2026 transitional deadline rather than the standard seven-month rule. Groups operating in or through the UAE should confirm:

1. Whether they’re in scope of Cabinet Decision No. 142 of 2024 for FY2025.
2. Which registration deadline applies to them — standard or transitional.
3. Whether a Domestic Designated Filing Entity should be appointed to centralize compliance across group entities.