On 7 October 2026, the United Arab Emirates Federal Tax Authority (FTA) published a comprehensive Top-up Tax Guide on Scope and Registration, marking a significant milestone in the UAE’s implementation of the OECD/G20 Inclusive Framework’s Pillar Two Global Anti-Base Erosion (GloBE) Rules. The guide provides detailed guidance to Multinational Enterprise (MNE) groups operating in the UAE regarding their obligations under Federal Decree-Law No. 60 of 2023 on the Top-up Tax on Multinational Enterprises, which aligns with the UAE’s commitment to the global minimum tax framework. The legislation introduces a Domestic Minimum Top-up Tax (DMTT) effective for fiscal years beginning on or after 1 January 2025, ensuring that large MNE groups with consolidated revenues exceeding EUR 750 million pay a minimum effective tax rate of 15% on profits arising in the UAE. The guide clarifies the scope of application, registration procedures, filing requirements, and the interplay with the UAE Corporate Tax regime enacted under Federal Decree-Law No. 47 of 2022.
Key Takeaways
- Scope Clarification and Registration Thresholds: The guide explicitly defines the MNE groups subject to the Top-up Tax, confirming the EUR 750 million consolidated revenue threshold and detailing the constituent entities covered, including Ultimate Parent Entities, Intermediate Parent Entities, and Partially-Owned Parent Entities resident in the UAE.
- Registration and Compliance Timeline: Affected MNE groups must register for Top-up Tax purposes through the EmaraTax portal within the prescribed regulatory deadlines. The guide outlines the registration process, required documentation, and the obligation to notify the FTA of any changes in group structure that may affect Top-up Tax liability.
- Interaction with UAE Corporate Tax and Foreign Tax Credits: The guidance addresses the coordination between the Domestic Minimum Top-up Tax and the standard UAE Corporate Tax, including the mechanism for claiming credit for qualified domestic minimum top-up taxes paid in other jurisdictions, thereby preventing double taxation and ensuring alignment with the GloBE Rules’ ordering rules.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement