The UAE's Domestic Minimum Top-up Tax (DMTT) has applied since financial years starting on or after 1 January 2025. It makes sure large multinational groups pay an effective tax rate of at least 15% on their UAE profits, in line with the OECD's Pillar Two rules.
Until recently, groups knew the tax applied but not how to register for it. FTA Decision No. 12 of 2026 now sets the registration, deregistration and notification rules, with a first deadline of 30 November 2026.
Who is in scope
The DMTT applies to UAE constituent entities of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding financial years. If your UAE company belongs to such a group, it is likely in scope, even if the UAE business itself is small.
The registration deadlines
- General rule: register within seven months after the end of the first financial year in which the entity is subject to Top-up Tax.
- Transitional rule: if that first financial year ended before 30 April 2026, register by 30 November 2026. For most groups with a calendar year, that means the 2025 year, so the deadline is 30 November 2026.
- Registration is required even if no top-up tax is payable, for example because the UAE effective tax rate is already above 15%.
Deregistration and notifications
- An entity that leaves the group or ceases to exist must apply to deregister within six months. If it ceased to exist before 30 June 2026, the deadline is 31 December 2026.
- Deregistration is approved only once all Top-up Tax returns and information returns are filed and all tax and penalties are paid.
- An entity that falls out of scope can file an out-of-scope notification within six months after the year end. An approved notification covers that year and the next four.
A Designated Filing Entity can file for the group
If the group appoints a Domestic Designated Filing Entity, it can submit registrations, deregistrations and notifications on behalf of the UAE entities in the group. That is usually simpler than every entity filing on its own.
What comes after registration
Registration is only the first step. Groups also need to prepare the Top-up Tax return and the GloBE Information Return. For the first year, these are generally due 18 months after the year end, so by 30 June 2027 for calendar year 2025. Check the FTA's guidance for the exact dates that apply to your group.
What to do now
- Confirm scope with your group tax team: consolidated revenue, UAE entities and the first in-scope year.
- Decide whether to appoint a Designated Filing Entity.
- Register in EmaraTax before 30 November 2026.
- Start collecting data for the effective tax rate calculation, which needs adjustments that go beyond the Corporate Tax return.
How Dreambooks helps
Dreambooks keeps each UAE entity's ledger, Corporate Tax adjustments and deferred tax data in one place, so group tax teams can pull the figures they need for Pillar Two calculations without chasing local spreadsheets.
Official sources
- FTA Decision No. 12 of 2026 on registration and deregistration timelines
- Cabinet Decision No. 142 of 2024 on Top-up Tax on multinational enterprises
- FTA: Corporate Tax legislation
This article is general information as of October 2026, not tax advice. Check FTA Decision No. 12 of 2026 and the latest FTA guidance, or speak to your tax adviser, before acting.