العربية
A key point in the FTA’s 3 November 2026 webinar was that a zero Top-up Tax outcome does not necessarily eliminate registration obligations. In-scope entities must register even where an applicable safe harbour or simplification deems their Top-up Tax to be zero.
The 15% minimum tax framework
The UAE DMTT is part of the OECD/G20 Pillar Two framework. The general threshold is consolidated annual revenue of at least EUR 750 million in two of the four immediately preceding fiscal years. Applicability depends on the entity’s classification and its position in the MNE group.
Safe harbours and simplifications discussed
- Transitional Country-by-Country Reporting Safe Harbour: may allow a deemed zero outcome where prescribed conditions are met.
- Simplified Calculations Safe Harbour: provides specified simplified calculations where available.
- De minimis exclusion: may deem Top-up Tax to be zero where jurisdictional conditions are satisfied.
- Initial phase of international activities: provides relief in qualifying circumstances under the applicable rules.
Does zero tax mean no registration?
No. The webinar expressly distinguished entities outside the charging provisions from entities subject to Top-up Tax whose liability is deemed zero under a safe harbour. The latter remain subject to registration.
Practical example
Consider an MNE group with consolidated revenue of EUR 900 million and a UAE subsidiary. If the UAE entity is within scope and qualifies for an applicable safe harbour, it may have zero Top-up Tax while still having a registration obligation.
What should businesses review?
- MNE group revenue and relevant consolidated statements.
- UAE entity classification and whether the charging provision applies.
- Eligibility and supporting calculations for each safe harbour.
- Registration requirements and filing obligations despite zero liability.
- Retention of evidence supporting the adopted tax position.
Safe harbour eligibility requires a separate technical assessment. A company should not assume that a zero payment position eliminates its administrative obligations.
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
