The Federal Tax Authority has issued Decision No. 12 of 2026 (issued 16 July 2026), setting out the registration and deregistration timelines for the UAE’s Domestic Minimum Top-up Tax (DMTT) under Cabinet Decision No. 142 of 2024. Until now, in-scope multinational groups knew they were liable to the 15% top-up tax from fiscal years starting 1 January 2025 — but had no prescribed date by which to register, a gap every corporate tax consultant advising MNE groups had been watching closely. That gap is now closed, and the first hard deadline is close: any entity whose first in-scope fiscal year ended before 30 April 2026 — which captures every calendar-year 2025 group — must submit its Top-up Tax registration application on or before 30 November 2026.
Effective date: The Decision came into effect on its date of issuance and applies to Fiscal Years starting on or after 1 January 2025 (Articles 7 and 8) — i.e., from the very first DMTT period. The 30 November 2026 transitional deadline is already running.
The context: the UAE DMTT and the missing procedural piece
Cabinet Decision No. 142 of 2024 imposes the UAE’s Pillar Two top-up tax on constituent entities of MNE groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years (the Article 1.1 scope test of the annexure), bringing their UAE effective tax rate to the 15% GloBE minimum for fiscal years starting on or after 1 January 2025. Article 13 of the annexure required in-scope entities to register with the FTA — but left the form, manner and timeline to the Authority. Decision No. 12 of 2026 supplies the timelines, and adds a notification architecture for groups that move in and out of scope as their revenues fluctuate.
Note what this registration is: a separate registration for Top-up Tax purposes, distinct from the entity’s existing Corporate Tax registration. Being CT-registered — as every UAE constituent entity already is, having completed its corporate tax registration in UAE — does not discharge it.
The deadlines at a glance
| Event | Timeline | Transitional rule |
|---|---|---|
| Registration — first in-scope Fiscal Year | 7 months from end of that Fiscal Year | FY ending before 30 Apr 2026 → register by 30 Nov 2026 |
| Deregistration — cessation or leaving the MNE Group | 6 months from the earlier trigger date | Ceased before 30 Jun 2026 → apply by 31 Dec 2026 |
| Out-of-scope notification (group falls below EUR 750m test) | 6 months from end of tested Fiscal Year; valid for that year + 4 more | — |
| In-scope notification (group re-enters scope) | 7 months from end of tested Fiscal Year | — |
| Deregistration after 5 consecutive out-of-scope years | 6 months from end of the fifth year | — |
Registration: seven months, with a transitional catch-up
The standing rule (Article 2(1)). An entity subject to Top-up Tax must apply for registration within seven months from the end of the first Fiscal Year in which it is in scope under Article 1.1. The seven-month period deliberately mirrors the in-scope notification deadline elsewhere in the Decision, creating one rhythm for scope-related filings.
The transitional rule (Article 2(2)). For entities whose relevant fiscal year ended before 30 April 2026, the deadline is fixed at 30 November 2026. This is the clause doing the immediate work: a calendar-year group’s FY2025 ended 31 December 2025, and the standing seven-month rule would have expired on 31 July 2026 — a fortnight after the Decision was issued. The transitional rule converts an impossible deadline into a real one. Groups with fiscal years ending 31 January, 28 February, or 31 March 2026 land on the same 30 November 2026 date; a group with a fiscal year ending 30 June 2026 falls under the standing rule, with registration due by 31 January 2027.
Who must register. The obligation attaches to an “Entity that is subject to Top-up Tax” in scope under Article 1.1 — and scope is the operative concept, not liability. A UAE constituent entity of an in-scope group should register even where it expects no top-up tax to be payable — because its UAE ETR already meets 15%, or because the transitional CbCR safe harbour zeroes the charge. Safe harbours switch off the tax computation; they do not remove the group from scope, and registration follows scope.
Deregistration: six months, but gated on full compliance
The standing rule (Article 3(1)). A deregistration application is due within six months from the earliest of: (a) the date the entity ceases to exist, or (b) the end of the fiscal year in which the entity leaves an MNE Group and thereby falls out of Article 1.1 scope. Entities that ceased to exist before 30 June 2026 have until 31 December 2026 (Article 3(2)).
The compliance gate (Article 3(3)). No deregistration is possible until the entity has settled all Top-up Tax and penalties and filed all Top-up Tax Returns and Pillar Two Information Returns due. The practical consequence is significant: the GloBE Information Return for the first in-scope year is not due until well after year-end (eighteen months for the transition year, fifteen months thereafter, per the international timeline Cabinet Decision 142/2024 adopts). An entity liquidated in 2025 may therefore submit its deregistration application within the deadline, but cannot complete deregistration until its final returns are filed — potentially into 2027. Liquidators should plan for the TRN to remain live long after the entity’s commercial death.
Continuity and FTA discretion (Articles 3(4)–(5)). An approved deregistration keeps the registration valid up to the earliest of cessation, the group-exit year-end, or another FTA-determined date — and where an entity qualifies for deregistration but never applies, the FTA may deregister it at its own discretion on the information available. Groups should not rely on that discretion; the six-month clock and its penalties belong to the taxpayer.
The in-scope / out-of-scope notification architecture
Because the EUR 750 million test is measured over two of the preceding four years, groups can drift out of scope and back in. Article 4 builds a five-year “parking” mechanism around that reality:
• Falling out of scope: where the MNE Group ceases to meet the Article 1.1 test for a tested fiscal year, each UAE entity submits an out-of-scope notification within six months of that year-end. The entity stays registered — dormant, not deregistered.
• Validity: the notification holds for the tested year plus four consecutive fiscal years.
• Coming back in scope: if the group re-enters scope during that validity window, an in-scope notification is due within seven months of the tested year-end — the same seven months as original registration.
• Exit after five years out: where the out-of-scope notification runs its full five consecutive years, the entity must then apply for deregistration within six months of the end of the fifth year.
The design is coherent with the revenue test’s own memory: a group that dipped below EUR 750 million can re-qualify for up to four years afterwards under the two-of-four-year rule, so the FTA keeps the registration alive across exactly that horizon before letting the entity leave the system.
One filer per group: the Domestic Designated Filing Entity
Article 5 confirms that where a Domestic Designated Filing Entity (DDFE) is appointed under Article 2.2 of the annexure, it submits the registration, deregistration, and scope notifications on behalf of all members of a Domestic Main Group, a Domestic Minority-owned Subgroup, a Reverse Hybrid Entity, or a Domestic JV Group. For MNE groups with multiple UAE entities this is the operative planning point: appoint the DDFE first, then file once — rather than having each subsidiary register separately. The DDFE appointment therefore now sits on the critical path to the 30 November 2026 deadline.
Worked example — the timeline in practice
Facts. Vertex Global Retail Group (calendar fiscal year) had consolidated revenue of EUR 820m (2021), 790m (2022), 760m (2023), 810m (2024). It operates three UAE subsidiaries and a UAE JV.
Registration. The group meets the EUR 750m test in at least two of the four years preceding FY2025, so its UAE entities are in scope from FY2025 — which ended 31 December 2025, before the 30 April 2026 pivot. Registration is due by 30 November 2026. The group appoints one subsidiary as DDFE, which registers on behalf of the Domestic Main Group and the Domestic JV Group in one exercise — a structuring decision Vertex takes jointly with its corporate tax consultants in Dubai.
Scope fluctuation. Suppose revenue falls to EUR 600m in 2026 and 2027, taking the group out of scope for FY2028 under the two-of-four test. The DDFE files an out-of-scope notification by 30 June 2029. The UAE entities remain registered. If revenue recovers so that the group is back in scope for FY2030, an in-scope notification is due by 31 July 2031. If instead the group stays out of scope through FY2032 — five consecutive years — the DDFE must apply for deregistration by 30 June 2033.
Cessation. If one UAE subsidiary was liquidated in March 2026, its deregistration application is due by 31 December 2026 under the transitional rule — but deregistration cannot complete until its FY2025 and stub-period Top-up Tax Returns and GloBE Information Returns are filed and any tax settled, which the group’s compliance calendar should carry into 2027.
Observations and open points
Registration despite safe harbours. The loudest trap in the Decision is groups assuming the transitional CbCR safe harbour excuses registration. It does not: scope, not liability, triggers the obligation, and groups paying zero top-up tax still face the 30 November 2026 date.
Penalty exposure. The Decision does not itself prescribe penalties; late registration falls to be sanctioned under the Tax Procedures framework and Cabinet Decision 142/2024’s penalty provisions. Given the FTA’s enforcement pattern on CT registration deadlines, groups should assume late DMTT registration will carry an administrative penalty and treat 30 November as hard.
Which entities within the group. The Decision speaks of “an Entity that is subject to Top-up Tax,” with the DDFE mechanism aggregating filings. Groups should map every UAE constituent entity — including reverse hybrids and JV structures, which Article 5 names expressly — against the annexure’s definitions before deciding the filing architecture, rather than assuming only the main operating companies are caught.
Departure versus shrinkage. Article 3’s deregistration triggers are cessation and leaving the group; Article 4’s notifications handle the group shrinking below the threshold. The two routes have different clocks (six months from different anchors) and different endpoints — mapping an entity’s exit to the correct route is the first classification step in any restructuring.
What in-scope groups should do now
Between now and 30 November 2026, MNE groups with UAE presence should: confirm Article 1.1 scope for FY2025 on the two-of-four revenue test (in euros, at the correct conversion); inventory every UAE constituent entity, JV, and reverse hybrid; decide and appoint the Domestic Designated Filing Entity so a single registration covers the group; register by the deadline even where safe harbours eliminate the liability; diarise the ongoing rhythm — seven months for registration and in-scope notifications, six months for out-of-scope notifications and deregistration; and, for any UAE entity ceasing or leaving the group, sequence liquidation and deregistration around the reality that final GloBE filings gate the exit.
How TSAC can help
TSAC, among the tax advisory firms active in the UAE Pillar Two space, advises multinational groups on UAE Pillar Two scoping, DMTT registration and compliance architecture, safe harbour analysis, and the interaction between the DMTT and Corporate Tax computations. The registration window to 30 November 2026 is generous only for groups that have already done the scoping work — for everyone else, the two-of-four revenue test, the entity inventory, and the DDFE appointment all sit between today and the deadline.
This publication is for general information only and does not constitute tax advice. Based on the unofficial English translation of FTA Decision No. 12 of 2026; the Arabic text prevails. Please contact TSAC for advice specific to your circumstances.