Plan · Global minimum tax
UAE entities of multinational groups with revenue of EUR 750 million or more are now subject to a Domestic Minimum Top-up Tax (DMTT) that brings their effective tax rate up to 15%. We confirm scope, register the entities, model the top-up tax and prepare the returns, starting with the registration the FTA has set for 30 November 2026.
Plan
What we do
We confirm whether the group meets the EUR 750 million test in two of the four preceding years, and which UAE entities are in scope, including free zone entities, using the FTA's guides on scope and registration (TTGREG1) and on excluded and investment entities (TTGEIE1).
We register each in-scope entity for Top-up Tax on EmaraTax, separately from its corporate tax registration, or register a Domestic Designated Filing Entity (DDFE) to act for the group.
We calculate the UAE effective tax rate and the top-up tax year by year from the group's data, applying the Commentary and Administrative Guidance adopted by Ministerial Decision No. 88 of 2025 and updated by Ministerial Decision No. 96 of 2026.
From 2026 tax periods, an approved R&D tax credit reduces corporate tax first and then Top-up Tax. Where the group runs qualifying R&D in the UAE, we build it into the model.
We prepare the return and the payment calculation, due 15 months after the year end, or 18 months for the first transition year.
We confirm whether the UAE entities must file the Pillar Two Information Return (PIR) or can rely on a filing by the group abroad, and prepare it where it falls to the UAE.
Entities joining or leaving, or the group falling out of scope, trigger their own notification and deregistration deadlines. We track them.
How it works
Day 1
At no charge, we confirm whether the UAE entities are in scope and what falls due first.
Typically 1 to 2 weeks
Group revenue history, the UAE entity list, ownership, free zone status and the data head office already holds.
Typically 1 to 2 weeks
Entity or DDFE registration on EmaraTax, with the FTA's questions answered.
Typically 3 to 6 weeks
The UAE effective tax rate and top-up tax, year by year, including the R&D credit where relevant.
Each financial year
The Top-up Tax return, the PIR where required and the payment, coordinated with head office.
What you get
Know the law
UAE entities of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding financial years are topped up to a 15% minimum effective tax rate, for financial years starting on or after 1 January 2025.
Cabinet Decision No. 142 of 2024; Federal Decree-Law No. 47 of 2022, Art. 3(3)
The FTA has set 30 November 2026 as the registration deadline for financial years ending before 30 April 2026; registration is required even if no top-up tax is due.
FTA Decision No. 12 of 2026
Outside the transitional rule, entities register within seven months of the end of their first in-scope financial year, and a DDFE may register and file for the group.
FTA Decision No. 12 of 2026
The Top-up Tax return and payment are due 15 months after the financial year end, or 18 months for the first transition year.
Cabinet Decision No. 142 of 2024, Arts. 8.1.2 and 11.1
For financial years beginning on or before 31 December 2026 and ending no later than 30 June 2028, no filing penalties apply where the FTA considers reasonable measures were taken; late payment is not covered.
Cabinet Decision No. 142 of 2024, Art. 14.3
UAE entities file a Pillar Two Information Return, or have a Designated Local Entity file for them, unless the ultimate parent or designated filing entity files in a jurisdiction with a qualifying competent-authority agreement and the FTA is notified.
Ministerial Decision No. 133 of 2026
Only if it belongs to a multinational group whose consolidated revenue was EUR 750 million or more in at least two of the four preceding financial years. Free zone entities in such a group are included. Below that threshold, the Top-up Tax does not apply and the ordinary corporate tax rules do.
Yes. Registration is required even if the top-up tax is nil, and it is separate from corporate tax registration. The FTA has set 30 November 2026 as the deadline for financial years ending before 30 April 2026, which covers a calendar FY2025. A Domestic Designated Filing Entity (DDFE) can register for the group's UAE entities.
For a calendar FY2025, on 30 June 2027. The return and payment are normally due 15 months after the financial year end, extended to 18 months for the first transition year. Payment falls due on the same date as the return.
That is not settled for the first year. Cabinet Decision No. 142 of 2024 sets 15 months after the year end, while some published guidance applies the 18-month transition period, and we have not been able to confirm the position from the implementing decision. Until the FTA confirms it, we plan to the earlier date. No UAE filing is needed if the group files in a jurisdiction with a qualifying competent-authority agreement and the FTA is notified.
For financial years beginning on or before 31 December 2026, no penalties apply for filing the Top-up Tax return or the PIR where the FTA considers that reasonable measures were taken. The relief covers filing only. Late payment of top-up tax is not covered, so the payment date still matters.
Yes. The R&D tax credit, available for tax periods starting on or after 1 January 2026, is used against corporate tax first and then against Top-up Tax. It is non-refundable, worth at most AED 2 million a period, and each project needs pre-approval by the Emirates Research and Development Council. A free zone entity can claim only where its R&D income is taxed at 9% or subject to Top-up Tax.
The FTA has set separate deadlines: notify within six months of falling out of scope, and deregister within six months of an entity ceasing to exist or leaving scope, once all top-up tax and penalties are settled. For entities that ceased before 30 June 2026, the FTA has set a transitional deadline of 31 December 2026.
Often needed together
Talk to us
Tell us the group's revenue history and its UAE entities. We will confirm whether they are in scope and what has to happen before 30 November 2026. The first conversation is free.
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