Regulatory Updates

UAE Top-Up Tax Registration and Deregistration Deadlines 2026: FTA Decision No. 12 Explained

12 min read

spawn ssh -o StrictHostKeyChecking=no -p 65002 u845330385@157.173.209.241 echo Y2QgZG9tYWlucy9xYXNwcm9nbG9iYWwuY29tL3B1YmxpY19odG1sICYmIHdwIHBvc3QgZ2V0IDM4NzUgLS1maWVsZD1jb250ZW50 | base64 -d | bash

u845330385@157.173.209.241’s password:

Published: 13 August 2026

Last updated: 19 August 2026

Quick Answer

The Federal Tax Authority’s Decision No. 12 of 2026 gives in-scope multinational groups 7 months from the end of their first in-scope fiscal year to register for UAE Top-up Tax (Domestic Minimum Top-up Tax, or DMTT), and 6 months to deregister after ceasing to exist or leaving the scope of an in-scope MNE Group. Entities whose first in-scope fiscal year ended before 30 April 2026 get an extended deadline of 30 November 2026 to register. A separate transitional deadline of 31 December 2026 applies to entities that ceased to exist before 30 June 2026. Deregistration is not granted until every Top-up Tax liability is settled and all required returns are filed.

If your group’s consolidated revenue is above EUR 750 million and you have a UAE constituent entity, this decision is the one that tells you exactly when to act, on EmaraTax, and what proof the FTA expects before it will let you off the hook.

What FTA Decision No. 12 of 2026 Actually Does

Decision No. 12 of 2026 was issued on 16 July 2026 and published on 4 August 2026. It does not create the Top-up Tax itself, that came from Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises, and Ministerial Decision No. 96 of 2026 (22 June 2026), which adopted the 2026 Consolidated Commentary, related Administrative Guidance, and the GloBE Information Return framework. What Decision No. 12 does is much narrower and much more practical: it sets the procedural clock, the exact deadlines for registration, deregistration, and mandatory notifications for entities already caught by the 15% Top-up Tax.

We covered who the Top-up Tax applies to and how the 15% rate works in our UAE Domestic Minimum Top-up Tax (DMTT) overview. This article covers what that overview does not: the actual registration and deregistration procedure, and the dates that make or break compliance.

The decision applies to fiscal years starting on or after 1 January 2025, and it abrogates any earlier provision that conflicts with it.

Who Must Register

Registration under Decision No. 12 applies to UAE constituent entities of a Multinational Enterprise (MNE) Group that is in scope of the Top-up Tax under Cabinet Decision No. 142 of 2024. In practice, that means:

The MNE Group’s consolidated group revenue is EUR 750 million or more in at least two of the four fiscal years immediately preceding the tested fiscal year (the standard Pillar Two revenue threshold).
The entity is a UAE-resident constituent entity, joint venture, or JV subsidiary of that in-scope group.
The entity falls within scope for the first time in a given fiscal year, which starts its own 7-month registration clock.

Registration is not automatic and is not bundled with your standard UAE Corporate Tax registration. Top-up Tax registration, filing, and payment obligations are handled as a separate track through the FTA’s EmaraTax platform, even for an entity that is already Corporate-Tax-registered.

The Registration Deadline: 7 Months From Fiscal Year End

The core rule is straightforward: an in-scope entity must submit its Top-up Tax registration application within 7 months from the end of the first fiscal year in which it falls within scope.

Example: if an in-scope entity’s first relevant fiscal year ends 31 December 2026, the registration application is due by 31 July 2027.

The 30 November 2026 Transitional Extension

Because the decision was only issued and published in mid-2026, and applies retroactively to fiscal years starting on or after 1 January 2025, the FTA built in a transitional extension so entities whose first in-scope fiscal year had already ended, or ended shortly after the decision’s publication, are not caught out by a deadline that had effectively already passed before the rules were public. Entities whose first in-scope fiscal year ended before 30 April 2026 have until 30 November 2026 to register, regardless of what the standard 7-month calculation would otherwise produce.

Table: Registration deadline logic

Situation	Registration deadline
First in-scope fiscal year ends on or after 30 April 2026	7 months from fiscal year end
First in-scope fiscal year ended before 30 April 2026	30 November 2026 (transitional extension)

The Deregistration Deadline: 6 Months

An entity that ceases to exist, or that leaves the scope of an in-scope MNE Group (for example, the group falls below the EUR 750 million threshold, or the entity is sold out of the group), must apply to deregister within 6 months of the triggering event.

The 31 December 2026 Transitional Deadline

A separate transitional rule addresses entities that had already ceased to exist, or already left scope, before the decision’s own compliance framework was in place. Entities that ceased to exist before 30 June 2026 have until 31 December 2026 to submit their deregistration application, rather than being deemed automatically late under the standard 6-month rule measured from an event that predates the decision.

Deregistration Is Not Automatic on Application

This is the part most businesses underestimate: submitting a deregistration application does not end the obligation. The FTA will not approve deregistration until the entity has:

Fully settled all Top-up Tax due, including any penalties.
Filed every required return, both the UAE Top-up Tax Return and the Pillar Two GloBE Information Return, for every period the entity was in scope.

An entity that stops trading, sells its UAE operations, or exits the MNE Group’s scope but leaves outstanding Top-up Tax returns unfiled will not be deregistered, and will continue to accrue exposure to late-filing and late-payment penalties until the record is complete.

In-Scope and Out-of-Scope Notifications

Beyond registration and deregistration, the decision also sets a notification requirement for entities whose in-scope or out-of-scope status changes. An entity that moves out of scope must notify the FTA within six months from the end of the Fiscal Year in which the change happened, and that out-of-scope status then holds for that year plus the following four years, five years in total, before it needs to be reassessed. If the entity re-enters scope before or after that five-year window, it must submit a fresh in-scope notification within seven months, the same timeline as an initial registration. This keeps the FTA’s record of who is currently in scope accurate between the less frequent registration and deregistration events, and is one of the more easily missed obligations because it does not come with the same visibility as a registration deadline.

The Domestic Designated Filing Entity

Decision No. 12 of 2026 also lets an MNE Group appoint one Domestic Designated Filing Entity to handle registration, deregistration, and notification obligations on behalf of every other constituent entity in the group that falls within the UAE Top-up Tax scope. Instead of each in-scope UAE entity separately registering, deregistering, or filing status notifications on EmaraTax, the group nominates one entity to do this centrally, and the FTA treats filings made by that entity as covering the whole group’s obligation for that filing. This does not remove any individual entity’s underlying tax liability, each constituent entity is still liable for its own Top-up Tax, it only consolidates the administrative filing step. Groups with several UAE entities in scope should decide who this Designated Filing Entity is early, since the appointment itself needs to be made and recorded with the FTA before it can be relied on for a registration or notification deadline.

How This Differs From Standard Corporate Tax Registration

	UAE Corporate Tax	UAE Top-up Tax (DMTT)
Governing law	Federal Decree-Law No. 47 of 2022	Cabinet Decision No. 142 of 2024 + FTA Decision No. 12 of 2026
Who it applies to	Nearly all UAE taxable persons	MNE Groups with EUR 750m+ consolidated revenue
Rate	9% (0% up to AED 375,000)	15% top-up on low-taxed profit
Registration deadline	Fixed by Corporate Tax registration timelines (FTA Decision No. 3 of 2024)	7 months from first in-scope fiscal year end
Deregistration proof required	Final return filed and tax settled	Full Top-up Tax settlement + all Top-up Tax and GloBE Information Returns filed
Platform	EmaraTax	EmaraTax (separate registration track)

A UAE entity can be, and often is, subject to both regimes at once. Being Corporate-Tax-registered does not satisfy the Top-up Tax registration requirement, and the two deadlines run independently.

What Happens If You Miss a Deadline

The decision does not itself set out a new penalty schedule, penalties for late Top-up Tax registration, late filing, and late payment follow the UAE’s existing Tax Procedures framework and the penalty schedule the Cabinet has issued for Top-up Tax specifically. In practice, that means the FTA can treat a missed registration deadline the same way it treats a missed Corporate Tax registration deadline: administrative penalties that accrue from the date the deadline passed, not from the date the FTA notices. For groups managing entities across multiple jurisdictions under Pillar Two, missing the UAE-specific registration window because the group’s global compliance calendar did not flag it separately is one of the most common gaps we see, since the UAE deadline runs on UAE-specific dates that do not automatically line up with the group’s home-jurisdiction Pillar Two calendar.

Practical Steps for In-Scope Groups

Confirm scope first. Check whether your group’s consolidated revenue met the EUR 750 million threshold in at least two of the last four fiscal years. If you are unsure, this is the starting point, not the registration form.
Identify your first in-scope fiscal year, and calculate your 7-month registration deadline from its end date, or apply the 30 November 2026 transitional deadline if that fiscal year ended before 30 April 2026.
Register through EmaraTax as a separate Top-up Tax registration, do not assume your existing Corporate Tax registration covers it.
Track any scope changes across the group during the year, a change in group revenue, ownership, or a UAE entity’s inclusion in the consolidated accounts can trigger a notification obligation even without a full registration or deregistration event.
Before applying to deregister, confirm every Top-up Tax Return and GloBE Information Return for every in-scope period has been filed and every liability settled, an incomplete filing history will hold up the deregistration regardless of how long ago the entity left scope.

Frequently Asked Questions

What is FTA Decision No. 12 of 2026?
It is the Federal Tax Authority decision, issued 16 July 2026 and published 4 August 2026, that sets the registration, deregistration, and notification deadlines for entities subject to the UAE’s Domestic Minimum Top-up Tax (DMTT) under Cabinet Decision No. 142 of 2024.

What is the deadline to register for UAE Top-up Tax?
7 months from the end of the first fiscal year in which the entity falls in scope. Entities whose first in-scope fiscal year ended before 30 April 2026 have until 30 November 2026 instead.

What is the deadline to deregister for UAE Top-up Tax?
6 months from the date the entity ceases to exist or leaves the scope of an in-scope MNE Group. Entities that ceased to exist before 30 June 2026 have until 31 December 2026.

Can an entity be deregistered before it has filed all its returns?
No. The FTA will not approve deregistration until the entity has fully settled all Top-up Tax due and filed every required Top-up Tax Return and Pillar Two GloBE Information Return for periods it was in scope.

Does this apply to every UAE company?
No. It only applies to constituent entities of MNE Groups with consolidated group revenue of EUR 750 million or more in at least two of the previous four fiscal years, the same threshold used across the OECD Pillar Two framework.

Is Top-up Tax registration the same as Corporate Tax registration?
No. They are separate registration tracks on EmaraTax, governed by different legislation, with independent deadlines. Being registered for Corporate Tax does not satisfy the Top-up Tax registration requirement.

What if my fiscal year ended before this decision was even published?
The transitional rule covers this. If your first in-scope fiscal year ended before 30 April 2026, your registration deadline is 30 November 2026 regardless of when the standard 7-month calculation would otherwise fall.

Do I need to notify the FTA if my entity’s in-scope status changes but I am not registering or deregistering that period?
Yes. The decision includes a separate in-scope and out-of-scope notification requirement, independent of the registration and deregistration events themselves.

What law created the 15% Top-up Tax itself?
Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises, supported by Ministerial Decision No. 96 of 2026 which adopted the relevant 2026 OECD Pillar Two administrative guidance.

Where do I register for UAE Top-up Tax?
Through the FTA’s EmaraTax platform, as a distinct registration from standard UAE Corporate Tax.

How Qaspro Global Can Help

Tracking a Top-up Tax deadline that runs on a different clock to your Corporate Tax calendar, across multiple UAE entities in a group, is exactly the kind of detail that gets missed when compliance calendars are managed manually. Qaspro Global helps in-scope groups confirm DMTT scope, calculate the correct registration and deregistration windows under FTA Decision No. 12 of 2026, and manage the EmaraTax filing itself.

Contact Qaspro Global on WhatsApp to review your group’s Top-up Tax registration position before a deadline is missed.