FTA Publishes Top-up Tax Guide on Scope and Registration for Multinational Groups

On 7 October 2026, the Federal Tax Authority issued a new Top-up Tax Guide on Scope and Registration and announced it through the Emirates News Agency, WAM. The guide gives multinational enterprise groups a single place to test whether the UAE's Qualified Domestic Minimum Top-up Tax, the QDMTT, applies to them and what registration duties follow if it does. The FTA wrote it for the people who run the tax affairs of entities that may belong to a multinational group, and for their tax agents.

The guide is practical rather than theoretical. It works through the scope conditions, the types of entity that are subject to the tax and the types that are not, and the registration process with its timelines. It also explains how to determine where an entity or permanent establishment is located, and it covers the filing of the Pillar Two Information Return.

A group falls inside the QDMTT when it meets the revenue test. The tax applies to constituent entities located in the UAE that belong to a multinational group with annual revenue of EUR 750 million or more, as shown in the consolidated financial statements of the ultimate parent entity, in at least two of the four fiscal years immediately before the fiscal year under review.

One carve-out matters to local businesses. A group that conducts its activities exclusively within the UAE stays outside the QDMTT legislation, whatever its revenue. The regime targets multinational structures, not domestic champions. The UAE built the QDMTT as part of the OECD and G20 Two-Pillar Solution, under the Global Anti-Base Erosion, or GloBE, model rules in Pillar Two. Those rules aim to make in-scope groups pay an effective tax rate of at least 15 percent in each jurisdiction where they operate. The OECD listed the UAE's regime in its central record on 18 August 2025 with transitional qualified status, which confirms the UAE collects the top-up on UAE profits itself instead of leaving it to other countries.

Scope questions rarely turn on the revenue figure alone. They turn on structure. The guide therefore spends much of its length on entity classification. It explains the treatment of constituent entities, permanent establishments, joint ventures, flow-through entities and hybrid entities, and the rules for deciding where each one is located. Location decides which jurisdiction's top-up tax applies, so the guide treats it as a question of fact and law, not a mailing address.

The worked examples show how the pieces combine. In one example, a group whose consolidated revenue exceeded EUR 750 million in two of four previous years is in scope, so its UAE companies form a domestic main group that must register, while a joint venture and its subsidiary form a separate domestic joint venture group with its own registration. Groups can register their UAE entities individually or appoint a domestic designated filing entity to act for a group. Each registered entity receives a Pillar Two top-up tax registration number.

Registration is the guide's most time-sensitive message. For in-scope entities whose fiscal years end before 30 April 2026, the registration deadline is 30 November 2026. That date is weeks away, and it catches the many groups whose first in-scope year ended on 31 December 2025. Groups that fall into scope later register within the timeline the guide sets by reference to the end of their first in-scope fiscal year.

Registration is separate from corporate tax registration, and a group must complete it even if it expects a safe harbour or the 15 percent calculation to produce no top-up tax payable. The filing side follows later: groups file a Pillar Two Information Return under the timelines the legislation sets after the fiscal year ends. Finance teams should separate the two duties in their compliance calendars. Missing the November registration date because the team focused on the later return deadline is exactly the error the guide exists to prevent.

Start with the revenue test. Ask the ultimate parent for the consolidated revenue figures for the last four fiscal years and record whether the EUR 750 million threshold was met in at least two of them. If the answer is yes, or close enough that currency conversion could change it, map every UAE entity, branch and joint venture against the guide's classification examples.

Then decide the registration route: individual registration for each entity, or a domestic designated filing entity for each domestic group. Confirm who inside the group owns the Pillar Two Information Return, because the data it needs, country-by-country figures, entity classifications and effective rate inputs, sits with group tax, not local finance. Groups with a December year-end should treat 30 November 2026 as a hard internal deadline with work starting now. The guide gives groups the method; it does not give them more time.