UAE Federal Tax Authority publishes Top-Up Tax registration guide

The Federal Tax Authority published a Top-up Tax Guide on Scope and Registration on 18 May 2025, setting out registration obligations and scope criteria for multinational enterprise groups under the Qualified Domestic Minimum Top-up Tax legislation. The guide addresses entities subject to the UAE Top-Up Tax, registration timelines and filing requirements for the Pillar Two Information Return. The QDMTT legislation applies to fiscal years beginning on or after 1 January 2025.

Scope and threshold criteria#

The Top-up Tax applies to constituent entities located in the UAE that are members of a multinational enterprise group with EUR 750 million or more in annual revenue, measured by the ultimate parent entity's consolidated financial statements for two of the preceding four fiscal years. Groups operating only within the UAE fall outside the scope regardless of revenue levels. The guide sets out criteria for determining whether an MNE group meets the QDMTT legislation requirements and identifies which entity types are subject to the tax and which are excluded.

Entity treatment and registration process#

The guide addresses the treatment of permanent establishments, joint ventures, flow-through entities and hybrid entities under the QDMTT legislation. It sets out registration requirements, procedures and applicable timelines for entities subject to the legislation. The guide covers the location determination of entities and permanent establishments for the purposes of the Top-up Tax. The guidance targets tax affairs personnel at entities potentially within an MNE group and tax agents.

OECD framework and transitional status#

The UAE QDMTT legislation implements the OECD/G20 Two-Pillar Solution addressing tax challenges from digitalisation of the economy. The Global Anti-Base Erosion Model Rules under Pillar Two require in-scope MNE groups to be subject to an effective tax rate of at least 15 percent in each jurisdiction through a top-up tax mechanism. The OECD central record added the UAE on 18 August 2025, assigning it transitional qualified status. The QDMTT legislation follows the GloBE Model Rules issued by the Organisation for Economic Co-operation and Development.

Practical guidance and examples#

The guide offers practical explanations and worked examples supporting comprehension of QDMTT legislation requirements. It covers the filing of the Pillar Two Information Return and registration procedures for entities within scope. The Federal Tax Authority published the guide to support multinational enterprise groups in understanding the application of the Top-up Tax in the UAE and their obligations under the relevant legislation effective from fiscal years beginning 1 January 2025.