The Federal Tax Authority has released a Top-up Tax Guide on Scope and Registration, aimed at helping multinational enterprise groups operating in the UAE understand whether they fall under the country’s Qualified Domestic Minimum Top-up Tax legislation and what their registration obligations are.
The QDMTT applies to constituent entities located in the UAE that are members of an MNE group with annual revenue of EUR 750 million or more, as reflected in the consolidated financial statements of the ultimate parent entity, in at least two of the four fiscal years immediately preceding the fiscal year under review. The legislation covers fiscal years beginning on or after 1 January 2025. Groups that operate exclusively within the UAE are outside the scope of the legislation, regardless of their revenue.
The UAE’s QDMTT forms part of the OECD/G20 Two-Pillar Solution, which targets a minimum effective tax rate of 15 percent for in-scope MNE groups in each jurisdiction where they operate. The UAE was listed in the OECD central record on 18 August 2025 with “transitional qualified” status.
The guide covers determining in-scope status, the types of entities subject to the tax and those that are not, permanent establishments, joint ventures, flow-through entities and hybrid entities, as well as registration procedures and timelines. It also addresses the filing of the Pillar Two Information Return.
The FTA said the guide is intended for those responsible for the tax affairs of entities that may be members of an MNE group, as well as tax agents, and should be read in full to understand how the different rules interact. Entities that may form part of an MNE group are encouraged to review their circumstances against the QDMTT requirements and consult the guide accordingly.
