UAE Federal Tax Authority issues new guide on Top-up Tax scope and registration

On 7 October 2026 the Federal Tax Authority (FTA) issued a new Top-up Tax Guide on Scope and Registration. The guide helps Multinational Enterprise (MNE) Groups understand whether they fall within the scope of the UAE's Qualified Domestic Minimum Top-up Tax (QDMTT) and what their registration obligations are, with practical explanations and examples. The FTA describes it as clear and practical guidance that allows businesses to meet their obligations with confidence, in support of voluntary compliance.

The key facts

• Background. The QDMTT forms part of the UAE's implementation of the OECD/G20 Two-Pillar Solution and applies to Fiscal Years beginning on or after 1 January 2025.
• International standing. The UAE was listed in the OECD central record on 18 August 2025 with "transitional qualified" status.
• Who is in scope. The tax applies to Constituent Entities located in the UAE that belong to MNE Groups with annual revenue of EUR 750 million or more in the Ultimate Parent Entity's consolidated financial statements, in at least two of the four Fiscal Years immediately preceding the Fiscal Year under consideration.
• Who is out of scope. Groups that conduct their activities exclusively within the UAE do not fall within the scope of the QDMTT legislation, irrespective of their revenue.
• What the guide covers. The conditions for scope; which entities are and are not subject to the tax; the treatment of Permanent Establishments, Joint Ventures, Flow-through Entities and Hybrid Entities; the location of Entities; registration requirements, procedures and applicable timelines; and the filing of the Pillar Two Information Return.
• Who it is for. Those responsible for the tax affairs of Entities that may be members of an MNE Group, and Tax Agents.

Why it matters for international clients

Many groups headquartered in Europe, North America and Australia run regional hubs, holding companies or operating subsidiaries in the UAE. For these groups, official guidance on scope and registration removes much of the uncertainty around how the UAE's top-up tax interacts with their group structure. It also confirms that purely domestic UAE groups are outside the regime regardless of size, which gives local founders and family businesses certainty.

The detailed treatment of joint ventures, flow-through and hybrid entities is particularly helpful for investment and holding structures, where the answer to "which entity is in scope, and where is it located?" is not always obvious.

What to do

• Confirm whether your group's consolidated revenue meets the EUR 750 million test in at least two of the four preceding Fiscal Years.
• Map each UAE entity and permanent establishment in the group, including joint ventures and any flow-through or hybrid entities, against the guide.
• Read the registration procedures and timelines in the guide and plan for the Pillar Two Information Return.
• Keep your UAE Corporate Tax position aligned with your Pillar Two analysis.
• Our CbCR and Pillar Two service and Corporate Tax service cover scoping reviews, registration and ongoing compliance. For a wider view of the UAE tax system, see our guides.

Sources

• Federal Tax Authority: Federal Tax Authority issues new guide on scope and registration for Top-up Tax on Multinational Enterprises (8 October 2026)
• Gulf News: UAE Federal Tax Authority issues guide on Multinational Enterprise Top-Up Tax (7 October 2026)

This page gives general information as at the date shown and is not advice for your specific situation. Rules in other countries are summarised for orientation; your home-country position should be confirmed before you act.