العربية
During its 3 November 2026 webinar, the Federal Tax Authority (FTA) emphasized timely registration under the UAE Domestic Minimum Top-up Tax (DMTT) regime. The first registration deadline is 30 November 2026. Late registration may trigger an AED 10,000 administrative penalty per entity.
What is UAE DMTT?
The UAE Domestic Minimum Top-up Tax implements part of the OECD/G20 Pillar Two framework, seeking a 15% minimum effective tax rate for in-scope multinational enterprise (MNE) groups. The UAE regime applies to fiscal years beginning on or after 1 January 2025.
Which companies are in scope?
The general revenue threshold is 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 tested fiscal year. A UAE subsidiary with modest standalone turnover may therefore be in scope because of its wider multinational group.
What is the registration deadline?
- Entities subject to Top-up Tax for any fiscal year ending before 30 April 2026: 30 November 2026.
- Other cases: within seven months from the end of the first fiscal year in which the entity is in scope.
What is the late-registration penalty?
The webinar notes specify AED 10,000 per entity. If a Domestic Designated Filing Entity (DDFE) misses registration for five entities, the potential combined penalty is AED 50,000.
Is registration necessary if no Top-up Tax is payable?
Yes. An entity subject to registration must register even when an applicable safe harbour deems the Top-up Tax amount to be zero. Being out of scope is different from being in scope with a zero tax outcome.
Action checklist
- Assess consolidated MNE revenue and the applicable fiscal years.
- Identify UAE Constituent Entities, relevant joint ventures and other covered entities.
- Determine whether to register individually or through a DDFE.
- Prepare signed group structure and authorization documents.
- Submit the EmaraTax application in advance of the applicable deadline.
How Hallmark can assist
Hallmark International Auditors & Accountants supports multinational groups with Pillar Two applicability assessments, DMTT registration, DDFE coordination, safe harbour reviews and ongoing tax compliance.
Dubai, UAE | 055 763 6758 / 04 259 9055
