Insights · UAE Compliance
UAE Top-up Tax (DMTT) Registration: Who Must Register by 30 November 2026
Which UAE entities of large groups must register for the Domestic Minimum Top-up Tax, the 30 November 2026 transitional deadline, and what Indian groups should do now.
If your group’s consolidated revenue is EUR 750 million or more, its UAE companies are probably within the UAE’s Domestic Minimum Top-up Tax, and most of them must register with the Federal Tax Authority by 30 November 2026. Registration is required even where the group expects to pay no top-up tax because a safe harbour applies, and even for free-zone companies that pay 0% corporate tax. The late registration penalty is AED 10,000 for each entity. For Indian groups with a Dubai trading arm or a free-zone holding company, this is a filing that is easy to miss because the UAE corporate tax return shows nothing due.
Key points
- The top-up tax applies for fiscal years starting on or after 1 January 2025, under Cabinet Decision No. 142 of 2024
- Scope: UAE entities of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years
- It tops up the group’s UAE effective tax rate to 15%
- Registration: within seven months of the end of the first in-scope fiscal year, and by 30 November 2026 for fiscal years ending before 30 April 2026 (FTA Decision No. 12 of 2026)
- Register even if the top-up tax is expected to be zero; AED 10,000 penalty per entity for late registration
Is your group in scope?
The test is the group’s consolidated revenue, not the UAE company’s. A UAE entity is in scope if it belongs to a multinational group whose consolidated revenue was EUR 750 million or more in at least two of the four fiscal years immediately before the year being tested. That is the same EUR 750 million line that triggers country-by-country reporting, so a group that already files a country-by-country report should assume its UAE entities are in scope. Certain excluded entities, such as government entities, international organisations, pension funds and some investment funds, sit outside the charge.
What the UAE entity pays in corporate tax does not decide the question. A Qualifying Free Zone Person paying 0% on qualifying income is exactly the kind of entity the top-up tax is aimed at, because its effective rate is below 15%.
The registration deadlines
| First in-scope fiscal year ends | Register by |
|---|---|
| Before 30 April 2026 (for example, 31 December 2025) | 30 November 2026 (transitional deadline) |
| 30 June 2026 | 31 January 2027 (seven months after year end) |
| 31 December 2026 | 31 July 2027 |
FTA Decision No. 12 of 2026 sets these deadlines. Registration is made through EmaraTax and is separate from corporate tax registration: a corporate tax registration number does not cover the top-up tax.
Who registers: each entity or a designated filer
Each in-scope UAE entity has the obligation, but a group can appoint a Domestic Designated Filing Entity to register on behalf of its UAE members. The convenience comes with a catch: if the designated entity misses an entity, the AED 10,000 penalty applies for each entity it failed to register, not once for the group.
Why a zero top-up tax still means registering
Many groups will owe nothing in the first years because a safe harbour applies, most commonly the transitional country-by-country reporting safe harbour, or the de minimis exclusion for small jurisdictions in the group. The FTA’s guidance is clear that these entities stay within the charging rules and must still register. Registration is how the FTA knows to expect the returns that show the safe harbour.
What comes after registration
The top-up tax return and the Pillar Two information return follow later. Under the Cabinet Decision the return is due 15 months after the end of the fiscal year, extended to 18 months for the first transition year, which puts the first return for a calendar-2025 group in mid-2027. Ministerial Decision No. 133 of 2026 deals with which entities file the information return. Confirm the exact dates for your group’s year end before relying on them, because the guidance is still being issued.
For Indian groups
- Check the group revenue test now, using the consolidated accounts of the ultimate parent for the last four years.
- List every UAE entity, including dormant companies, free-zone holding companies and branches; each one counts.
- Decide whether to appoint a designated filing entity and record the appointment.
- Collect the data for the safe harbour test from the group’s country-by-country report, so the first return can rely on it.
- Align the transfer pricing: top-up tax is computed from the same UAE profits that the related-party pricing produces. See UAE transfer pricing thresholds.
The corporate tax side is covered in UAE corporate tax explained and UAE corporate tax return deadlines and penalties. Our UAE corporate tax team handles top-up tax scoping, registration and the first returns for Indian groups.