العربية
1. What is UAE DMTT?
The Domestic Minimum Top-up Tax implements the UAE’s part of the Pillar Two framework, targeting a minimum effective tax rate of 15% for in-scope multinational groups.
2. What is the revenue threshold?
EUR 750 million or more in consolidated annual revenue in at least two of the four immediately preceding fiscal years, subject to applicable adjustments.
3. When did UAE DMTT take effect?
For fiscal years beginning on or after 1 January 2025.
4. Does DMTT apply to every UAE company?
No. It applies to specified entities in in-scope multinational groups. Groups operating exclusively within the UAE are not within the QDMTT scope.
5. Is the threshold based on the UAE subsidiary’s revenue?
No. It is generally based on the Ultimate Parent Entity’s consolidated financial statements.
6. What is the first registration deadline?
30 November 2026 for entities subject to Top-up Tax for any fiscal year ending before 30 April 2026.
7. What is the deadline in other cases?
Within seven months from the end of the first fiscal year in which the entity is in scope.
8. What is the late-registration penalty?
AED 10,000 per entity; a DDFE may incur the penalty separately for each entity not registered on time.
9. Must an entity register if Top-up Tax is zero?
Yes, if it is subject to registration, including where a safe harbour deems the tax to be zero.
10. What is a DDFE?
A Domestic Designated Filing Entity that undertakes specified domestic administrative functions, including group registration.
11. Can a DDFE register multiple entities?
Yes. It may submit one application covering relevant domestic group entities.
12. How is a DDFE authorized?
Through an authorization letter or an EmaraTax acknowledgement.
13. What is the acknowledgement deadline?
14 business days; an unanswered request is automatically cancelled.
14. Is there a group registration government fee?
The webinar indicated no fee for the group registration application.
15. What documents are needed?
Depending on circumstances, UPE identification/TIN evidence, group structure, DDFE or DLE authorizations and signatory documents.
16. Do documents need to be in English?
Non-English documents should have English translations attached, as stated during the webinar.
17. Must the corporate structure be signed and stamped?
The webinar identified unsigned or unstamped charts as a cause of application rejection or delay.
18. When is the Top-up Tax Return due?
Generally within 15 months of the Reporting Fiscal Year end, or 18 months for the qualifying first Transition Year.
19. How long are records retained?
Seven years.
20. What is a DLE?
A Designated Local Entity may be appointed for Information Return or notification functions under the applicable rules.
21. Are joint ventures potentially in scope?
Yes. UAE joint ventures and JV subsidiaries can be subject to the rules where statutory conditions are met.
22. Must registration be updated after group changes?
Yes. Relevant changes, including DDFE changes or entity transfers, must be reflected and notified as required.
