UAE Opens Pillar Two Top-up Tax Registration on EmaraTax: What MNE Groups Should Do Now

The UAE has activated Pillar Two top-up tax registration on the EmaraTax portal, moving the country’s 15 percent domestic minimum top-up tax from legislation into administration. We explain who must register, how the two registration routes work, the deadlines and penalty relief currently in place, and the steps in-scope multinational groups should take now.

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The United Arab Emirates has taken the next operational step in implementing the OECD’s global minimum tax. The Federal Tax Authority (FTA) has enabled Pillar Two top-up tax registration on the EmaraTax portal, allowing, and in due course requiring, UAE constituent entities of in-scope multinational enterprise (MNE) groups to register under the country’s Domestic Minimum Top-up Tax (DMTT) framework.

The DMTT was introduced through Cabinet Decision No. 142 of 2024, which gives effect to the OECD’s Global Anti-Base Erosion (GloBE) Model Rules in UAE law. It applies to fiscal years starting on or after January 1, 2025 and imposes a top-up tax on UAE entities of MNE groups whose effective tax rate in the country falls below 15 percent, ensuring that any top-up tax due on UAE profits is collected by the UAE rather than by another jurisdiction under a foreign income inclusion rule. With the registration function now live, the compliance cycle for the first fiscal year has formally begun.

Who falls within the scope of the UAE DMTT?

The DMTT applies to entities that are members of MNE groups with annual revenues of EUR 750 million (US$ 857 million or more) in the consolidated financial statements of the ultimate parent entity in at least two of the four fiscal years immediately preceding the tested year. The threshold is assessed at group level: a UAE subsidiary with modest local revenue is still in scope if the wider group crosses the line, and this includes free zone entities benefiting from a 0 percent corporate tax rate on qualifying income. Entities may also fall within scope as a result of a merger, acquisition, or demerger.

The regime contains targeted carve-outs consistent with the GloBE rules. Investment entities are excluded, a substance-based income exclusion reduces the profit base subject to top-up tax by reference to payroll and tangible assets, a de minimis exclusion can deem the top-up tax to be zero for smaller operations, and transitional relief applies during the initial phase of a group’s international activity in defined circumstances. Groups must retain the records used to determine their DMTT position for seven years from the end of the relevant tax period.

How does registration on EmaraTax work?

Registration is conducted through the EmaraTax portal and begins with a preliminary questionnaire that determines whether registration is required; entities outside the scope of the rules cannot submit an application. In-scope groups must then choose between two routes for managing their Pillar Two obligations in the UAE.

The choice determines how compliance responsibility, documentation, and payment obligations are allocated across the group, and it also dictates the supporting documents required at registration. Under the DDFE route, every nominating entity must provide its authorization through EmaraTax before the DDFE can submit the completed application, making early internal coordination essential. Particular attention should be paid to identifying all UAE constituent entities, including joint ventures and permanent establishments, whose details are specifically requested during the registration process.

What deadlines and penalties apply?

The FTA has not yet announced a registration deadline, and further guidance on filing timelines, payment procedures, notifications, and the penalty framework is expected. The filing obligations themselves, however, are already defined: in-scope entities must submit a top-up tax return within 15 months of the end of the relevant tax period, extended to 18 months for the transitional first year, meaning a group with a December 31, 2025 year-end faces its first filing by June 30, 2027. The Pillar Two information return follows the OECD’s standardized GloBE Information Return template, adopted in the UAE under Ministerial Decision No. 88 of 2025.

A transitional penalty relief applies: no penalties will be imposed for filing the top-up tax return or the information return for fiscal periods beginning on or before December 31, 2026 (and not ending after June 30, 2028), provided the group has taken reasonable measures to apply the rules correctly. The relief does not extend to late payment of an actual top-up tax liability, and outside the relief window, DMTT non-compliance is penalized under the UAE’s corporate tax penalty regime.

Key takeaways for MNE groups

Although no registration deadline has been set, the opening of the EmaraTax function is the clearest signal yet that the UAE’s Pillar Two administration is operational, and in-scope groups should treat readiness as a current-year task rather than a 2027 one. The immediate priorities are to confirm whether the group meets the EUR 750 million (US$857 million) threshold, map every UAE constituent entity including joint ventures and permanent establishments, and decide – at group level – whether to appoint a DDFE before individual entities begin registering independently, since a coordinated approach avoids duplicate or unnecessary registrations.

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Equally important is the data exercise behind the filings: the GloBE calculations can require several hundred data points per entity, and groups should verify that the financial information gathered for registration is consistent with the Pillar Two positions reported at group level and disclosed in the consolidated financial statements.

With FTA guidance on deadlines and administrative procedures still to come, in-scope groups should monitor announcements closely – but those that assemble their entity mapping, governance decisions, and data infrastructure now will be well placed to register and file smoothly whenever the deadlines land.

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