Requirements for registration and deregistration of entities for domestic minimum top-up tax (DMTT) purposes

In July 2026, the UAE Federal Tax Authority (FTA) issued Decision No. 12 that establishes registration and deregistration procedures for the purposes of domestic minimum top-up tax imposed on multinational enterprise (MNE) groups. The decision applies to financial years starting on or after 1 January 2025.

Registration

An entity that is subject to top-up tax shall submit a registration application within seven months from the end of the first fiscal year in which the entity is in scope of DMTT.

An entity with a fiscal year ending before 30 April 2026 shall submit a DMTT registration application on or before 30 November 2026.

Deregistration

An entity shall submit a deregistration application for DMTT purposes within six months from the earlier of the following dates: the date it ceases to exist, or the end of the fiscal year in which it leaves an MNE group.
An entity ceasing to exist before 30 June 2026 shall submit a deregistration application for DMTT on or before 31 December 2026.

If the FTA deregisters a taxpayer, its tax registration remains valid until the earliest of the following dates: the date of cessation of the entity, the end of the fiscal year in which the entity leaves an MNE group, or any other date as may be determined by the FTA.

Where the registrant meets the deregistration requirements, the FTA may, at its discretion and based on the information available to it, deregister the entity without it submitting a relevant application.

An entity may not be deregistered unless it has settled in full all tax liabilities and penalties, and filed all tax returns and other required information.

In-scope and out-of-scope notifications

Entities that are members of MNE groups must notify the tax authorities of their DMTT status:

Becoming out-of-scope

If an MNE group ceases to be in scope for the tested fiscal year, its member shall submit an out-of-scope notification within six months from the end of that fiscal year.

The notification remains valid for the tested year and the subsequent four consecutive fiscal years, unless the entity is required to revert to in-scope.

Reverting to in-scope

If an entity previously submitted an out-of-scope notification, which was valid in the preceding year, but the MNE group is again in scope in the current tested year, the entity shall submit an in-scope notification within seven months from the end of the tested fiscal year.

Deregistration upon expiry of five years

Where an out-of-scope notification remains valid for five consecutive fiscal years, an entity shall submit a deregistration application within six months from the end of the fifth year, unless it is required to submit an in-scope notification.

Designated filing entity

Where members of an MNE group appoint a designated filing entity pursuant to Article 2.2 of the annexure to Cabinet Decision No. 142 of 2024, this entity assumes responsibility for submitting all applications and notifications on behalf of the group.

The right to appoint a designated filing entity is granted to members of:

• Domestic main groups and domestic minority-owned subgroups
• Domestic JV groups
• Reverse hybrid entities.

How we can help

• Advising on the application of Pillar 2 rules (domestic minimum top-up tax) and assessing their impact on the group structure in the UAE
• Assisting entities in preparing and submitting registration and deregistration applications for domestic minimum top-up tax purposes
• Calculating the amount of domestic minimum top-up tax payable by members of MNE groups.