If your group’s UAE entities sit inside a multinational group earning €750 million or more a year, a registration deadline is approaching fast: in-scope entities with fiscal years ending before 30 April 2026 must register for the UAE’s 15% minimum top-up tax — the Qualified Domestic Minimum Top-up Tax (QDMTT) — by 30 November 2026.

The Federal Tax Authority (FTA) has issued detailed guidance on registration and filing under the regime — and the guidance includes one point that surprises many finance directors: groups operating exclusively inside the UAE are outside the scope entirely, no matter how large their revenue. This guide walks through the scoping question, the deadlines, the registration process, and what the Pillar Two Information Return requires.

What Is the UAE’s Pillar Two / QDMTT Regime?

Pillar Two is the OECD/G20 global minimum-tax framework: large multinational groups must pay an effective tax rate of at least 15% in every jurisdiction where they operate. The UAE implemented it through Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises, applying to fiscal years starting on or after 1 January 2025.

The UAE’s version is a Qualified Domestic Minimum Top-up Tax: if a multinational group’s UAE entities collectively pay less than 15% effective tax on their UAE profits, a top-up tax brings the UAE rate up to the 15% floor — collected by the FTA, not by another country’s revenue authority. That is the main strategic point: complying in the UAE keeps the top-up tax in the UAE rather than leaving it to be collected elsewhere.

Are You In Scope? The Three-Part Test

Start with this checklist. An entity is in scope only if all three hold:

1. Group revenue threshold. The group has consolidated revenue of €750 million or more in at least two of the four financial years immediately preceding the relevant fiscal year. This is a group test, not an entity test.
2. Multinational, not domestic-only. The group must include at least one entity outside the UAE. Groups conducting their activities exclusively within the UAE are outside the scope, regardless of revenue.
3. Fiscal year timing. The regime applies to fiscal years starting on or after 1 January 2025.

The FTA’s guidance also clarifies the treatment of constituent entities, permanent establishments, joint ventures, flow-through entities and hybrid entities — so groups with complex structures should check each entity type individually rather than assuming the parent-company analysis covers the group.

QDMTT Registration Deadlines

The headline date: 30 November 2026. The full rule:

Two things worth noting. First, registration is separate from corporate tax registration — being registered for UAE corporate tax does not cover this. Second, registration may be required even if a safe harbour means your top-up tax comes out at zero — the obligation attaches to being in scope, not to owing money.

How to Register: EmaraTax and the Designated Local Entity

Registration is completed through the FTA’s EmaraTax portal. The framework for registration, deregistration and notification obligations was set by FTA Decision No. 12 of 2026.

For groups with multiple UAE entities, note the Designated Local Entity concept: certain filing and information-return obligations can be handled by one designated entity on behalf of the others, which simplifies compliance for groups — but each constituent entity’s registration position still needs to be tracked individually, since penalties apply per entity.

The Pillar Two Information Return: Who Files

Beyond registration, the regime requires a Pillar Two Information Return filed with the FTA. Ministerial Decision No. 133 of 2026 (25 August 2026) sets out exactly who must file it:

• Each Constituent Entity located in the UAE (excluding Investment Entities);
• Each Joint Venture and JV Subsidiary located in the UAE; and
• Each stateless Constituent Entity that is a reverse hybrid entity created in accordance with UAE law.

The return may be filed directly by the entity or by its Designated Local Entity on its behalf. The first return is due 15 months after the fiscal year-end — or 18 months for the first transition year. For a group with a 31 December 2025 year-end, that puts the first return at 30 June 2027, with payment due alongside it.

Penalties and the Cost of Missing 30 November

Published advisor guidance reports an administrative penalty of AED 10,000 for each entity not registered on time, with the penalty applied per entity — so a group with several UAE constituent entities can face a large combined exposure (a group with five UAE entities, for example, could face AED 50,000).

One important distinction: the FTA has indicated a penalty relief window for late Top-up Tax Returns and Pillar Two Information Returns — for fiscal years beginning on or before 31 December 2026 (and not ending after 30 June 2028), no penalty applies where the group can show reasonable measures to comply. That relief does not cover late payment of the tax itself, and it does not cover the AED 10,000 late-registration penalty. In other words, the relief window is no excuse to miss the 30 November registration deadline.

QDMTT Scoping Checklist: 5 Steps Before 30 November

1. Confirm multinational status. If every entity in the group is inside the UAE, you are out of scope — document the conclusion.
2. Run the €750m revenue test on consolidated revenue for the four years before the relevant fiscal year; you need two years at or above the threshold.
3. List every UAE entity — constituent entities, PEs, JVs, flow-through and hybrid entities — and check each against the FTA guidance.
4. Fix your registration position. Register via EmaraTax before 30 November 2026 where your fiscal year ends before 30 April 2026; appoint a Designated Local Entity where it helps.
5. Start the data pipeline for the Information Return. The first return (30 June 2027 for Dec-2025 year-ends) needs GloBE-compliant data your ERP may not produce today — begin the mapping now.

Running this alongside your other tax deadlines? Businesses with revenue of AED 50 million+ must also appoint an e-invoicing Accredited Service Provider by 30 October 2026 — see our UAE e-invoicing guide.

FAQs: UAE Pillar Two Tax (QDMTT)