FTA Prescribes Registration Timelines Under the UAE Pillar Two Regime
 

Key Deadline: 30 November 2026 | For Entities whose first in-scope Fiscal Year ended before 30 April 2026

FTA Decision No. 12 of 2026 prescribes registration, deregistration, and notification timelines for entities subject to the UAE Pillar Two Top-up Tax regime under Cabinet Decision No. 142 of 2024.

Background

Cabinet Decision No. 142 of 2024 introduced the UAE Top-up Tax for Fiscal Years beginning on or after 1 January 2025. The regime forms part of the UAE's implementation of the OECD Pillar Two framework. Generally, it applies to Constituent Entities of a Multinational Enterprise (MNE) Group with consolidated annual revenue of EUR 750 million or more in at least two of the four Fiscal Years preceding the tested Fiscal Year.

Key Definitions

• In-scope - An Entity is in scope for a tested Fiscal Year if it is subject to the UAE Top-up Tax regime under Article 1.1 of the Annexure to Cabinet Decision No. 142 of 2024.
• Out-of-scope - An Entity is out of scope for a tested Fiscal Year if its MNE Group ceases to be in scope under Article 1.1. The Entity must notify the FTA within six months of that Fiscal Year-end.
• DDFE - A Domestic Designated Filing Entity appointed under Cabinet Decision No. 142 of 2024 to submit relevant registration, deregistration, and in-scope or out-of-scope notifications for specified UAE group members.

Registration and DDFE

• An in-scope Entity must apply for Tax Registration within seven months from the end of its first in-scope Fiscal Year.
• Where a DDFE is appointed, it must submit the relevant applications or notifications for members of a Domestic Main Group, Domestic Minority-owned Subgroup, Reverse Hybrid Entity, or Domestic JV Group.

Other Key Timelines

• Deregistration within six months from the relevant cessation or scope-exit event.
• Out-of-scope notification within six months from the end of the tested Fiscal Year; valid for that year and the next four consecutive Fiscal Years, unless re-entry occurs.
• Re-entry into scope requires an in-scope notification within seven months from the end of the tested Fiscal Year.

Indicative Registration Deadlines

First in-scope Fiscal Year ending	Registration deadline
31 December 2025	30 November 2026
31 March 2026	30 November 2026
30 April 2026	30 November 2026
30 June 2026	31 January 2027
30 September 2026	30 April 2027
31 December 2026	31 July 2027

Note

The transitional deadline applies where the first in-scope Fiscal Year ends before 30 April 2026. A Fiscal Year ending on 30 April 2026 follows the ordinary seven-month rule, which also results in a 30 November 2026 deadline.