FTA Activates Pillar Two Registration Functionality on Emara Tax Portal
 

The Federal Tax Authority (FTA) has recently activated the Pillar Two registration functionality on the Emara Tax portal, indicating the UAE tax authorities' continued progress toward implementation of the OECD's Global Anti-Base Erosion (GloBE) framework and the Domestic Minimum Top-up Tax (DMTT) regime in the UAE.

The registration tab is now visible on the EmaraTax portal for entities that may potentially fall within the scope of Pillar Two provisions. We await formal notification of the process and relevant guides from the FTA governing the registration process. The notification/guide would address certain open areas like:

• Registration timelines and due dates;
• Scope of entities required to register;
• Filing Mechanics and Administrative Provisions.

The development is nevertheless significant, as it reflects the authorities' intention to operationalize the Pillar Two compliance framework in the UAE. Multinational Enterprise (MNE) Groups meeting the prescribed consolidated revenue threshold should therefore proactively assess their Pillar Two applicability and readiness from a data, governance, and compliance perspective.

Key Action Points for Businesses

• Assess whether the group falls within the Pillar Two threshold requirements;
• Identify UAE-based constituent entities potentially impacted by the DMTT regime;
• Review data availability and collate information relevant for registration. Some critical data points include the detailed corporate group structure, determining the designated domestic filing entity, and preparing a list of all other constituent entities in the UAE.
• Monitor forthcoming guidance and regulatory announcements from the UAE authorities.

Who May Be Impacted?

The registration requirement is expected to apply to MNE groups meeting the EUR 750 million consolidated revenue threshold prescribed under the Pillar Two framework. UAE constituent entities within such groups should assess and meet their potential obligations under the DMTT regime.