FTA Publishes Top-up Tax Guide: What It Means for UAE Businesses

The Federal Tax Authority announced on 7 October 2026 that it has issued a new Top-up Tax Guide on Scope and Registration (TTGREG1). The guide explains who falls under the UAE’s Top-up Tax on Multinational Enterprises, also called the Qualified Domestic Minimum Top-up Tax (QDMTT), and how in-scope entities register with the FTA.

For most UAE small businesses the short answer is reassuring: this tax is aimed at very large international groups. But the guide also confirms that size in the UAE is not the test. A small UAE company can be in scope because of who owns it, and the first registration deadline is 30 November 2026.

What is the UAE Top-up Tax?

The Top-up Tax is the UAE’s part of the OECD/G20 Pillar Two rules, which aim to make sure large multinational groups pay an effective tax rate of at least 15% in each country where they operate. The legal basis is the Corporate Tax Law as amended by Federal Decree-Law No. 60 of 2023, together with Cabinet Decision No. 142 of 2024. It applies to Fiscal Years beginning on or after 1 January 2025.

It sits inside the Corporate Tax framework but has its own registration, returns and Pillar Two Information Return.

Which businesses are in scope?

According to the guide, the Top-up Tax applies to Constituent Entities located in the UAE that are members of a multinational group with annual revenue of EUR 750 million or more in the consolidated financial statements of the ultimate parent entity, in at least two of the four Fiscal Years before the year being tested.

Two points matter for SMEs and their accountants. First, the EUR 750 million test is applied at group level, not to the UAE company. A UAE subsidiary with modest local revenue is still in scope if its foreign parent group crosses the threshold. Second, the group must be international. The guide states that purely domestic UAE groups, with entities located only in the UAE, are outside the scope even if their consolidated revenue is above EUR 750 million.

Certain entities are not subject to Top-up Tax at all, including government entities, international organisations, non-profit organisations, pension funds, and investment funds or real estate investment vehicles that are the ultimate parent. Investment Entities located in the UAE are also excluded.

When must in-scope entities register?

Registration for Top-up Tax is separate from Corporate Tax registration. The guide is clear that an entity subject to Top-up Tax must register “regardless of whether they are registered for Corporate Tax purposes.” Applications are made on EmaraTax, and each registered entity receives a Pillar Two Top-up Tax TRN. Where the entity is already registered for another tax, the new TRN uses the same first 10 digits as its existing Tax Registration Number.

The timelines come from FTA Decision No. 12 of 2026:

Registration is still required where the Top-up Tax is deemed to be zero, for example under the de minimis exclusion or the transitional Country by Country Reporting safe harbour. A group can register entity by entity or appoint a Domestic Designated Filing Entity (DDFE) to register, file and pay for all its UAE members. This works differently from a Corporate Tax tax group, so existing Corporate Tax grouping does not replace a Top-up Tax registration.

What happens if an entity does not register on time?

The guide states that an administrative penalty of AED 10,000 applies where an entity fails to submit its registration application within the required timeline. Where a DDFE misses the deadline, AED 10,000 applies for each entity it failed to register. The FTA can also register an entity on its own initiative, effective from the date it should originally have registered.

What should UAE business owners and accountants check now?

If your company is wholly UAE owned and has no entities or branches abroad, you can note this guide and move on. If your UAE company is owned by a foreign group, ask the group finance or tax team two questions this month: did the consolidated group reach EUR 750 million in revenue in two of the last four years, and who is handling the UAE Top-up Tax registration?

Accountants serving UAE subsidiaries of international groups should add this to their October checklist alongside Corporate Tax registration checks, since the 30 November 2026 deadline lands before many year-end reviews.

Naqood is FTA-accredited accounting software for UAE businesses. Clean, up to date books make it easier to give a parent group the local figures it needs for group tax reporting.

Official source: Top-up Tax Guide on Scope and Registration (TTGREG1), published on the FTA Corporate Tax guides page.

Frequently asked questions about the UAE Top-up Tax

Does the UAE Top-up Tax apply to small businesses?

Only if the small business is part of a multinational group with consolidated revenue of EUR 750 million or more in at least two of the four previous Fiscal Years. The UAE company’s own revenue does not decide it. Purely domestic UAE groups are out of scope whatever their size.

What is the deadline to register for Top-up Tax in the UAE?

For an entity whose first in-scope Fiscal Year ended before 30 April 2026, the deadline is 30 November 2026. In other cases, the application is due within 7 months from the end of the first Fiscal Year in which the entity is in scope.

Do I need to register if my Top-up Tax is zero?

Yes. The guide confirms that entities still count as subject to Top-up Tax where it is deemed zero under the de minimis exclusion or the safe harbour rules, so they must still register.

Is Top-up Tax registration the same as Corporate Tax registration?

No. It is a separate registration on EmaraTax with its own Pillar Two Top-up Tax TRN. Being registered for Corporate Tax does not cover it.

This article is for general information and does not constitute tax or legal advice. For how the rules apply to your specific situation, consult a qualified UAE tax adviser. Naqood is an FTA-accredited accounting platform for UAE businesses.