UAE DMTT Registration Guide (2026) | Requirements, Rules, Deadline & Pillar Two Compliance

If your business is part of a multinational Group, then 2025 might have quietly created a new tax obligation you just haven’t registered for yet. The Domestic Minimum Top-up Tax (DMTT) in the UAE is now in full effect. Its requirement for registration isn’t even optional for such global businesses, and the clock is already running.

Federal Decree-Law No. 60 of 2023 set the foundation on which the Cabinet Decision No. 142 of 2024 introduced the DMTT law. The goal of this law is simple: large multinational Groups must pay at least 15% tax on their profits, no matter where they run operations from.

But here’s a bit of relief, local SMEs and startups that operate within the Emirates may not necessarily feel the effect. The rules aim to target global Groups that earn at least €750 million in annual consolidated revenue. If your organisation sits inside these “target” Groups – even as a small subsidiary, the obligation could just already apply to you.

What is Domestic Minimum Top-up Tax (DMTT) in the UAE?

The all-new Domestic Minimum Top-up Tax UAE regime is here to ensure that qualifying multinational Groups pay at least 15% effective tax on all profits that have been generated within the Emirates.

This new law came into play through Cabinet Decision No. 142 of 2024, and the rules began to take effect for financial years starting from January 1st, 2025.

To make the DMTT easier to understand, think of it as a correction mechanism. If the effective tax rate for a qualifying Group that makes profits in the UAE is below 15%, an additional amount becomes payable to close that gap. That extra payment is the top-up tax.

Particulars	Amount
UAE Profit	AED 100 million
Effective Tax Paid	9%
Minimum Required Rate	15%
Difference	6%
Estimated Top-Up Tax	AED 6 million

What is Qualified Domestic Minimum Top up Tax (QDMTT)?

The QDMTT is simply a domestic tax regime that meets the standards set by the OECD Pillar Two framework. It’s a deliberate design of the DMTT by the UAE to be able to achieve this qualification.

Without a properly recognised domestic regime, any other country where the qualified Group operates could step in and collect the top-up tax instead. By having this QDMTT in place, the UAE is able to retain the right to collect any applicable top-up on profits made within the state.

What Does a “Group” Mean Under The Pillar Two Rules?

Here is where most businesses often miss it, and place themselves in the wrong category by assuming they fall outside the scope.

Under the law guiding Taxation of Corporations and Businesses, a Group is a collection of entities that are related through ownership or control, where assets, liabilities, income, expenses, and cash flows are:

• Included in the Consolidated Financial Statements of the Ultimate Parent Entity, or
• Excluded from those statements solely on size or materiality grounds, or because the entity is held for sale

A Group also will include a single entity that is in one jurisdiction but has one or more Permanent Establishments in other jurisdictions, provided that the entity is not part of another Group.

Note:

If an entity is excluded from the consolidated statement of a Group simply because its size is considerably immaterial, it might just still count.

Do You Need to Worry About Pillar Two Tax in UAE?

For most businesses that are reading this, the honest answer is no.

The UAE Pillar Two Tax is mainly for multinational Groups. Not precisely for locally trading companies with UAE-only operations or businesses without cross-border Group structures.

Who Must Register for Pillar Two Top-Up Tax?

Under Federal Decree-Law No. 60 of 2023 and Cabinet Decision No. 142 of 2024, the following entities are to pay the Top-up Tax for a fiscal year as required:

• Constituent Entities that were within the UAE during that fiscal year, which will include members of a minority-owned subGroup
• Joint Ventures and JV Subsidiaries that were in the UAE during that fiscal year
• Stateless Constituent Entities that have been created under the laws in the UAE that are Reverse Hybrid Entities, with respect to their Pillar Two income or loss.

But beyond the type of entity, the rules sort of apply to global enterprise Groups that:

• Generate consolidated annual revenue of at least €750 million.
• Meet that revenue threshold in at least two of the previous four fiscal years.
• Have one or more entities that operate in the UAE.
• Fall within the scope of the UAE DMTT framework.

Note: Measuring eligibility is almost always at the Group level, not company level. A UAE subsidiary earning a modest local revenue can probably fall within scope if the wider Group crosses the global threshold.

What is the Top-up Tax Revenue Threshold Requirements in the UAE?

Whether or not a business falls within scope actually just depends on the size of the entire multinational Group, not just the scale of the UAE entity itself.

The DMTT in the UAE applies to multinational Groups that have at least €750 million in consolidated annual revenue, that is measured across at least two of the previous four fiscal years. It’s a threshold that has been adopted directly from the OECD Pillar Two model and incorporated into UAE law.

Understanding the €750 Million Threshold

The €750 million test is a Group-wide test, and what a UAE entity really even earns locally is not the determining factor.

Scenario	Subject to DMTT?
Company that earns AED 50 million, operates only in the Emirates	No
Free Zone company that earns AED 200 million, not part of a multinational Group	No
Subsidiary that belongs to a multinational Group with €1.2 billion global revenue	Yes
Parent company that controls a global Group with €900 million revenue	Yes
Entity excluded from consolidation on materiality grounds but part of qualifying Group	Yes

Most businesses tend to miss the last scenario. Exclusion from consolidated statements on materiality grounds does not equal exclusion from Pillar Two obligations.

Who Could Most Likely Be Exempt?

A few entities might just qualify for exclusions under UAE and OECD model rules.

• Government entities
• International organisations
• Pension funds
• Certain investment funds
• Certain real estate investment vehicles

How to Register for Top-Up Tax Through EmaraTax

EmaraTax is the online platform for tax registration as guided by the Federal Tax Authority in the UAE. Once a business has confirmation that they fall within the scope, it’s time to login into the EmaraTax for their Top-up Tax registration.

What to Prepare Before You Begin

Have these ready:

Document	Purpose
Trade Licence	Entity identification
Corporate Tax Registration Details	Existing tax records
Group Ownership Chart	Group structure verification
Parent Entity Information	Revenue threshold assessment
Financial Statements	Revenue confirmation
JV and Subsidiary Details	Full Group scope confirmation
Authorised Signatory Information	Registration authorisation

Once in the platform, there’s an opening questionnaire that will route you into one of two registration paths.

• Domestic Designated Filing Entity (DDFE). This is for Groups with multiple UAE entities.
• Individual Entity Registration. This is for a single UAE entity.

Path 1: DDFE Registration

Step 1: Questionnaire

This is where you select DDFE registration and confirm that your company actually meets the €750 million threshold. 

Step 2: Multinational Enterprise (MNE) Group Information

Here you are to provide all necessary information

• Enter your Group name
• Show the first reporting fiscal year dates
• Highlight the details of the Ultimate Parent Entity

You’ll have to upload corporate structure documents to support the information provided.

Step 3: DDFE Details

Enter the TIN and name of the designated filing entity. You will also at this point confirm PE, any Excluded Entity, and Investment Entity status.

Step 4: Authorised Signatory

To confirm that you are filling the details for your company, you will write out your full name in English and Arabic, enter your Emirates ID or passport number, and email address registered to the FTA.

Step 5: Review and Submit

Ensure that you review all the information provided is accurate. Make the required declaration and submit for approval.

Path 2: Individual Entity Registration

Step 1: Questionnaire

This path, you are to select Individual registration. You will also need to confirm your company meets the threshold, then choose your Group type.

• Domestic Main Group
• Domestic Minority-Owned Subgroup
• Reverse Hybrid Entity
• Domestic JV Group

Step 2: MNE Group Information

(Same process as DDFE Step #2)

Step 3: Constituent Entity/JV Details

Here you are to provide the details about your company. TIN, confirm PE, Excluded Entity, and Investment Entity status. You may also need to appoint a Designated Local Entity, if applicable.

Step 4: Authorise Signatory and Submit

Enter your signatory details, review all your progress during registration, declare, and submit.

The following paths reflect the registration flow as understood at the time of writing. Always refer to tax.gov.ae or contact the FTA directly to get the most current interface guidance.

After Submitting

Submissions don’t guarantee instant confirmation. The FTA still reserves the right to request additional information before the registration process is fully finalised. Your role will be to monitor the EmaraTax account regularly and respond to any requests that could be needed in a prompt manner.

UAE DMTT Registration Deadline

Requirement	Details
Who Must Register?	Multinational Enterprise (MNE) Groups with global consolidated revenue of at least €750 million in at least two of the previous four fiscal years.
Registration Platform	Registration must be completed separately through EmaraTax and is distinct from standard UAE Corporate Tax registration.
FTA Registration Deadline	The UAE Federal Tax Authority (FTA) has not yet prescribed a specific deadline for obtaining a Pillar Two Top-up Tax registration.
First DMTT Return Deadline	For the transitional period covering the financial year ending 31 December 2025, the first DMTT return must be filed by 30 June 2027.
Standard Filing Timeline	DMTT returns must generally be filed within 15 months after the end of the relevant reporting fiscal year.
Minimum Tax Rate	The UAE DMTT imposes a 15% minimum effective tax rate on qualifying multinational groups under the OECD Pillar Two framework.
Compliance Recommendation	Businesses should assess their eligibility, register through EmaraTax, and prepare for reporting obligations well before the filing deadline.

What Are The Reporting Requirements and Penalties for Non-Compliance with DMTT?

Completing this registration, which is mandatory for qualified Groups, actually opens the door to compliance regulations.

After registration is complete, businesses must maintain records, prepare calculations, and satisfy all ongoing obligations that are required for reporting.

The purpose is to allow the FTA to be able to verify whether the Group consistently meets the 15% minimum effective tax rate required under UAE Pillar Two Tax rules.

What are the Penalties for Non-Compliance?

Failing to comply with DMTT UAE requirements will result in penalties, as guided under Cabinet Decision No. 75 of 2023 and updated Cabinet Decision No. 10 of 2024.

Based on current applicable penalties, businesses that do not comply are likely to face:

• Late registration — AED 10,000
• Late filings of tax return — AED 500 per month for the first 12 months. AED 1,000 per month from month 13 onwards.
• Late payment of due tax — 14% per annum
• Failure to maintain required records — AED 10,000 per violation
• Incorrect tax return — AED 500 for first violation, AED 2,000 for repeat

How The Pillar Two Rules Impact Multinational Groups in the UAE?

The impact most of the time depends on the structure of the precise Group in question. This is also coupled with what their effective tax rate is and their operations within the UAE.

Here are a few examples of instances where the Pillar Two rules will apply for multinational enterprise Groups.

1. A Foreign Group That Has a Subsidiary in the UAE 

A European multinational Group that generates around €2 billion in annual revenue and operates through a subsidiary that is in the UAE, that Group meets the revenue threshold. Now, even if the subsidiary in the UAE sort of earns a relatively small local revenue, it will most likely need to register and report through EmaraTax.

2. A Company That Operates in a Free Zone, But is Part of a Multinational Group

A Free Zone company already kind of benefits from a favourable tax position under UAE Corporate Tax rules. What changes now is that it belongs to a multinational Group that surpasses the revenue threshold, but it remains relevant for Pillar Two calculations.

Free Zone status does not exempt such businesses from their obligations to DMTT.

3. An Entity That Has Been Excluded on Materiality Grounds

A UAE entity that has been excluded from the Consolidated Financial Statements of its Group because its contribution was deemed “too small.” Under the “Group” definition in Federal Decree-Law No. 60 of 2023, the entity could actually fall within the scope of the DMTT.

Exclusion from consolidation on materiality grounds is not the same as exclusion from Pillar Two obligations.

Why Professional Tax Advisory Support Matters?

The Pillar Two Rules that governs businesses across the Emirates aren’t complicated just simply because the concept is hard to grasp. What actually makes it a bit complex is that applying these sets of rules to real Group structures requires careful analysis that goes beyond simply checking a revenue figure.

This is where a professional tax advisor comes into play. The role of an expert here will be to help your business to:

• Determine whether the DMTT rules apply to the specific Group structures that you have chosen.
• Assess how JVs, minority-owned subgroups, and Permanent Establishments are treated.
• Complete the entire EmaraTax registration for you accurately and on time.
• Review the QDMTT calculations before filing.
• Build every single piece of documentation that is needed to support compliance over time.
• Identify and address the risks before they become regulatory problems.

At Tax Consultant Dubai, we help businesses to navigate their tax obligations in the UAE. Our team of experts has served over 30,000 clients across 150 countries, and we totally understand what multinational Groups that operate in the UAE actually face.

Book a free consultation today and get to speak with experts who have experience in maintaining compliance while giving you practical advisory support.

FAQs

Who Is Subject to Pillar Two Tax in UAE?

The Pillar Two tax in the UAE actually applies to every single multinational enterprise Group that has at least €750 million in consolidated annual revenue in more than two of the previous four fiscal years. Of course, this will include Constituent Entities in the UAE, Joint Ventures and JV Subsidiaries, and Stateless Constituent Entities that are Reverse Hybrid Entities.

How Does UAE DMTT Work?

The Domestic Minimum Top-up Tax in the UAE is there to ensure that every qualifying Group pays at least 15% effective tax on profits that have been made within the Emirates. If the effective levy of a Group falls below 15%, an additional top-up tax becomes payable to close that gap.

Let’s say for example, a qualifying Group that pays 10% may face an additional 5% top-up to reach the required minimum.

What Is the UAE Top-Up Tax Threshold?

The Top-up Tax threshold for the UAE is around about €750 million in consolidated annual Group revenue. A Group must meet this in at least two of the previous four fiscal years. This rule applies to the entire multinational Group worldwide, not the individual entity that operates in the UAE in isolation.

Is DMTT Applicable to Free Zone Companies?

In some cases, yes. Free Zone status does not automatically exempt a company from DMTT. If such a Free Zone entity belongs to a multinational Group that has gone above the revenue threshold, it might actually need to assess its Pillar Two obligations. 

Does UAE Corporate Tax Satisfy Pillar Two Requirements?

Not automatically. The UAE Corporate Tax and the Pillar Two models are separate systems that have different objectives and means by which they are calculated. Pillar Two models often place their focus more on whether the effective tax rate for a Group has reached the global minimum of 15%, which is different from what the Corporate law upholds.