UAE Top-Up Tax registration: who must register by 30 November 2026, the date for your fiscal year, and what to prepare

If your UAE company belongs to a multinational group and its fiscal year ended before 30 April 2026, it must apply to register for Top-up Tax by 30 November 2026 (Article 2(2), Federal Tax Authority Decision No. 12 of 2026). Any other entity has seven months from the end of its first in-scope fiscal year.

What changed. The FTA issued Decision No. 12 on 16 July 2026; the Ministry of Finance added Ministerial Decision No. 133 on 3 August 2026, which says who files the Pillar Two Information Return, the group-level report that goes with Top-up Tax. On 7 October 2026 the FTA announced a guide on scope and registration; we read the announcement page, not the guide itself. This page reads the texts as of 11 November 2026.

Who is in scope

Top-up Tax is the UAE's domestic minimum tax for large multinational groups, part of the OECD's Pillar Two rules. The minimum rate in Cabinet Decision No. 142 of 2024 is 15%. The test for registering is a group test, not a company test:

• The entity is a UAE member of a multinational (MNE) group: a group with at least one entity or permanent establishment outside the country of its ultimate parent.
• The group's annual revenue in the ultimate parent's consolidated financial statements is EUR 750 million or more in at least two of the four fiscal years before the year being tested.
• The rules apply to fiscal years starting on or after 1 January 2025.
• The entity is not an Excluded Entity under Article 1.5 of Cabinet Decision No. 142 (for example a government entity, non-profit organisation, pension fund, or an investment fund or real estate investment vehicle that is the ultimate parent). Check this with your tax adviser.

A group that operates only in the UAE is out of scope, whatever its revenue, according to the FTA's guide announcement. The EUR 750 million test is applied proportionally to a fiscal year that is not 12 months. Nothing in your UAE ledger can answer the test alone: the revenue figure sits in the parent's consolidated statements, so the group tax team owns that answer.

Your deadline, by fiscal year-end

Decision No. 12 gives two rules. The standard rule is seven months from the end of the first fiscal year in which the entity is in scope. The transitional rule moves every entity with a year-end before 30 April 2026 to 30 November 2026. Our calculation, applying both rules:

The 30 November date is 17 days after this page goes live. If your entity was in scope for a fiscal year that began in 2025 and ended before 30 April 2026, it is the date to plan to.

Who submits: the entity or one filing entity for the group

Registration is in the form and manner the FTA prescribes. Where the group appoints a Domestic Designated Filing Entity, Decision No. 12 lets that entity submit the registration application, deregistration application and notifications for all members of a domestic main group, a domestic minority-owned subgroup, a reverse hybrid entity or a domestic joint venture group. Agree who that is before 30 November, and confirm in writing that the FTA's records show it.

The FTA may also register an entity itself from the date the entity was required to register, using the information it holds (Cabinet Decision No. 142, Article 13.2). Do not wait for it.

After you register: three clocks

Penalties are the open question. Decision No. 12 sets no amount. Cabinet Decision No. 142 applies the Corporate Tax Law's article on assessment and penalties to Top-up Tax. For fiscal years beginning on or before 31 December 2026 (not including a fiscal year that ends after 30 June 2028), it removes penalties on the two returns where the FTA considers the group took reasonable measures to apply the rules correctly. That relief names the returns; it does not mention registration. We found no registration-specific penalty in the texts we read (Decision 12, Cabinet Decision 142, Ministerial Decision 133), so treat 30 November as a hard date.

What to prepare this week

1. Ask your group tax lead whether you are in scope. The answer comes from the parent's consolidated statements for the four preceding years.
2. List every UAE entity in the group, including joint ventures, with its legal name, trade licence, Corporate Tax registration and fiscal year-end.
3. Put each entity's date in your calendar from the table above, and mark the 30 November ones.
4. Decide the filing entity. One designated entity can register for a domestic group; name it, and hold the board or group-tax approval.
5. Start the data trail for the returns. Fiscal year-end revenue, payroll and tangible assets by entity, with the source ledger for each figure. Start from the figures your ledger holds; the group tax team adds the consolidation adjustments the returns require.

How Tarleaks helps

Tarleaks Accounting keeps the ledgers of each legal entity in a workspace and reports the group as one set of consolidated statements without writing to the entities' own books. That gives your tax team a traceable source for entity-level figures. Tarleaks does not compute Top-up Tax, prepare the Pillar Two Information Return or register an entity with the FTA; your tax adviser and the FTA's portal do that.

What to do next

• Read the Decision: FTA Decision No. 12 of 2026, Articles 2 to 5.
• If your UAE company is not part of a multinational group, check the other 2026 duties in our UAE e-invoicing timeline and the Small Business Relief guide.
• Book a demo to see consolidated statements for several legal entities, with sample data.

Questions people ask

What is the UAE Top-up Tax registration deadline?

30 November 2026 for an entity whose fiscal year ended before 30 April 2026, under FTA Decision No. 12 of 2026. For any other entity it is seven months after the end of the first fiscal year in which the entity is in scope, for example 31 December 2026 for a year ending 31 May 2026.

Who must register for Top-up Tax in the UAE?

UAE members of a multinational group whose parent's consolidated statements show revenue of EUR 750 million or more in at least two of the four preceding fiscal years. A group that operates only in the UAE is out of scope. Your group tax team confirms the test; a UAE ledger cannot see the parent's consolidated revenue.

Does one entity register for the whole UAE group?

It can. Where a Domestic Designated Filing Entity is appointed, Decision No. 12 lets it submit the registration, deregistration and notifications on behalf of all members of a domestic main group, a domestic minority-owned subgroup, a reverse hybrid entity or a domestic joint venture group.

Is there a penalty for registering late?

Decision No. 12 sets no amount. Cabinet Decision No. 142 applies the Corporate Tax Law's penalty article to Top-up Tax, and its relief for reasonable measures names the two returns, not registration. We found no registration-specific penalty in the texts; confirm with the Federal Tax Authority.

What comes after registration?

A Top-up Tax Return and a Pillar Two Information Return, each no later than 15 months after the end of the fiscal year. The only extension is for the Top-up Tax Return: 18 months in a group's first transition year. The Information Return stays at 15 months. Notifications follow if the group goes out of scope.

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General information, not legal or tax advice. Checked against the official sources listed on this page on 11 November 2026. The FTA's copy of Decision No. 12 is marked as an unofficial translation; the Official Gazette text governs. Confirm your position with the Federal Tax Authority or your tax adviser.