UAE clarifies top-up tax scope and registration deadlines

Who must register

TTGREG1 explains the registration mechanics for the UAE domestic minimum top-up tax, which applies for fiscal years beginning on or after 1 January 2025. The rules generally cover multinational enterprise groups with consolidated revenue of at least EUR750 million in at least two of the four fiscal years preceding the tested year.^[1][2][3]

In-scope UAE constituent entities generally register individually. A group may instead appoint a domestic designated filing entity for specified obligations, but the guide’s conditions and entity-level information requirements still need to be met. The FTA also states that registration can remain necessary where a safe harbour or exclusion reduces the eventual top-up tax to zero.^[1][3]

Registration timetable

FTA Decision No. 12 of 2026 sets the registration deadlines. For a first in-scope fiscal year ending before 30 April 2026, the deadline is 30 November 2026. In other cases, registration is generally due within seven months after the end of the first fiscal year for which the entity is subject to the top-up tax.^[3][4]

The decision’s timetable should be applied entity by entity. The guide explains that restructurings, acquisitions, disposals, joint ventures and changes to group scope can affect which UAE entities must register and the information they must provide. Groups should not assume that an ultimate-parent registration outside the UAE satisfies the domestic requirement.^[3][4]

Practical consequence

The administrative penalty for late registration is AED10,000 for each affected entity. UAE groups should reconcile their legal-entity population, fiscal-year end, revenue history and designated-filer arrangements before the applicable deadline, including entities expected to have no cash top-up tax because of a safe harbour. The 7 October announcement is new publicity for an August guide; it is administrative guidance, not a new enactment of the underlying top-up tax.^[1][2][3][4]