The UAE’s Pillar Two compliance framework continues to take shape. The Federal Tax Authority (FTA) Decision No. 12 of 2026, issued on 16 July 2026, sets out the timelines for registration and deregistration for UAE Top-up Tax purposes under Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises. For multinational groups operating in the UAE, the Decision provides an important piece of the compliance calendar: when an in-scope entity must register, when it must deregister, and what happens when a group temporarily falls outside the scope of the UAE Top-up Tax regime.
The UAE Top-up Tax regime applies for Fiscal Years beginning on or after 1 January 2025.
Who should pay attention?
The UAE Top-up Tax regime is relevant to Constituent Entities of multinational enterprise groups meeting the applicable Pillar Two revenue threshold. Broadly, the QDMTT legislation applies to MNE Groups having annual consolidated revenue of EUR 750 million or more in at least two of the four Fiscal Years immediately preceding the tested Fiscal Year. However, meeting the group revenue threshold does not necessarily mean that every UAE entity has identical Top-up Tax obligations. The entity’s status under the UAE Pillar Two legislation must also be assessed.
For example, certain Excluded Entities and Investment Entities do not have Top-up Tax registration obligations.
1. When must an entity register for UAE Top-up Tax?
FTA Decision No. 12 of 2026 provides a clear general rule: An entity subject to Top-up Tax must submit its registration application within seven months from the end of the first Fiscal Year in which the entity is in scope. For example, if an entity first becomes in scope for a Fiscal Year ending 31 December 2026, the seven-month rule would generally result in a registration deadline of 31 July 2027.
Important transitional deadline: 30 November 2026
The Decision contains an important transitional provision for the initial implementation period. Where an entity has a Fiscal Year ending before 30 April 2026, its Top-up Tax registration application must be submitted:
on or before 30 November 2026.
Accordingly, for many multinational groups following a 31 December year-end, the first UAE Pillar Two registration deadline will be 30 November 2026. This is likely to be one of the most immediate Pillar Two compliance dates for affected UAE businesses.
2. When is deregistration required?
Registration is only one part of the compliance cycle. An entity must generally submit a Top-up Tax deregistration application within six months from the earliest of:
- the date on which the entity ceases to exist; or
- the end of the Fiscal Year in which the entity leaves an MNE Group and is no longer within the scope of the applicable Top-up Tax provisions.
There is also a transitional provision. Where an entity ceased to exist before 30 June 2026, its deregistration application must be submitted on or before:
31 December 2026.
3. Outstanding tax and returns must be cleared before deregistration
An entity cannot simply deregister and leave its outstanding Pillar Two compliance behind.
Before deregistration, it must have:
- settled all outstanding Top-up Tax
- settled applicable penalties
- filed all outstanding Top-up Tax Returns; and
- filed all outstanding Pillar Two Information Returns.
This makes it important for businesses to perform a complete Pillar Two compliance review before applying for deregistration.
4. What if an MNE Group temporarily becomes out of scope?
One of the more interesting features of Decision No. 12 is that falling outside the Top-up Tax scope does not necessarily mean immediate deregistration. The Decision introduces an Out-of-Scope Notification mechanism. Where the relevant MNE Group ceases to be in scope, the entity generally submits an Out-of-Scope Notification to the FTA within the prescribed period. The notification can remain valid for the relevant Fiscal Year and the following four consecutive Fiscal Years.
This creates a practical distinction between:
permanently leaving the regime and temporarily becoming out of scope.
If the entity subsequently comes back within scope, an In-Scope Notification is required within the applicable timeline. Where the entity remains out of scope for the full prescribed period, deregistration requirements then become relevant. This mechanism is particularly useful for multinational groups whose consolidated revenue may fluctuate around the Pillar Two threshold.
5. Registration is not the same as filing the Top-up Tax Return
Businesses should also distinguish between three separate Pillar Two compliance concepts:
Top-up Tax Registration
↓
Pillar Two Information Return
↓
Top-up Tax Return and payment
FTA Decision No. 12 principally addresses the registration and deregistration timeline. It should not be interpreted as making the 30 November 2026 transitional registration deadline the deadline for filing the first Top-up Tax Return. These are separate obligations under the UAE Pillar Two framework.
What should UAE businesses do now?
Multinational groups with UAE operations should begin identifying their Pillar Two population rather than waiting for the registration deadline.
In practical terms, businesses should:
- Confirm whether the MNE Group meets the EUR 750 million consolidated revenue threshold.
- Identify all UAE entities within the Group.
- Determine which UAE entities are within the scope of the UAE Top-up Tax rules.
- Separately assess whether any entities qualify as Excluded Entities or Investment Entities.
- Determine the first in-scope Fiscal Year for each relevant entity.
- Identify the applicable FTA registration deadline.
- Establish responsibility for UAE Pillar Two registration, information reporting, Top-up Tax Return preparation and payment.
- Maintain a central UAE Pillar Two compliance calendar.
Key deadlines at a glance
Requirement | Deadline |
First Top-up Tax registration | Within 7 months after end of first in-scope Fiscal Year |
FY ending before 30 April 2026 | Registration by 30 November 2026 |
Entity ceases to exist | Deregistration generally within 6 months |
Entity leaves MNE Group and is no longer in scope | Generally within 6 months from relevant FY-end |
Entity ceased to exist before 30 June 2026 | Deregistration by 31 December 2026 |
The registration and deregistration deadlines above are expressly set out in FTA Decision No. 12 of 2026.
Conclusion
For many calendar-year multinational groups already within the UAE Pillar Two regime, the date to put on the compliance calendar is:
30 November 2026 – transitional UAE Top-up Tax registration deadline
But registration should be the end of the assessment process, not the beginning. Before registering, multinational groups should understand which UAE entities are in scope, which may be excluded, who will manage the UAE Pillar Two filings, and how the UAE requirements interact with the Group’s global Pillar Two reporting process. RVG Chartered Accountants can assist multinational groups with UAE Pillar Two scope assessments, entity mapping, registration, compliance planning and Top-up Tax advisory.
Disclaimer: This article is intended for general informational purposes only and should not be considered tax or legal advice. The application of UAE Pillar Two rules depends on the specific facts and structure of each multinational group.
Also Read: New UAE VAT Supplier Verification Rules from 1 October 2026
