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/ TAX 22 Sep 2026 · 6 min read

Pillar Two arrives: the UAE Top-up Tax and who must register by 30 November.

A second, separate tax now applies to the largest multinational groups, with a registration deadline many will hit on 30 November 2026. It is the UAE Top-up Tax, the local Pillar Two. Here is what it is and who must register when.

FW Global Insights — The UAE Top-up Tax

Most of the UAE tax conversation is about the 9% Corporate Tax, but a second, separate tax now applies to the largest multinational groups, and it carries a registration deadline that is easy to miss: 30 November 2026 for many of them. It is the UAE Top-up Tax, the local version of the global minimum tax often called Pillar Two. If your business is part of a large multinational group, this is a deadline to check now. Here is what the tax is and who has to register when.

What the Top-up Tax is

The UAE introduced a Domestic Minimum Top-up Tax through Cabinet Decision No. 142 of 2024, applying for fiscal years starting on or after 1 January 2025. It implements the global minimum tax agreed internationally: large multinational groups should pay an effective tax rate of at least 15% in each country they operate in. Where the UAE effective rate on a group's local profits falls below 15%, a top-up brings it up to that level. It sits alongside, not inside, the ordinary Corporate Tax.

Who is in scope

This is not a tax for most businesses. It targets large multinational enterprise groups, broadly those with consolidated global revenues of EUR 750 million or more in at least two of the four preceding financial years. A purely domestic business, or a smaller group, is outside it. But a UAE entity that is part of a qualifying global group is in scope, even if the UAE entity itself is modest, and that is the case businesses miss.

The registration deadlines that just landed

FTA Decision No. 12 of 2026, issued in July 2026, sets the registration, deregistration, and notification timelines. The headline dates are specific.

ActionDeadline
Register (in scope)Within 7 months of the end of the first fiscal year in scope
Register (early year-ends)Entities with a fiscal year ending before 30 April 2026 register on or before 30 November 2026
DeregisterWithin 6 months of ceasing or leaving the group and being out of scope
Out-of-scope notificationWithin 6 months of the tested year end; valid for that year and four more
The Top-up Tax is separate from the 9% Corporate Tax, and its registration deadline is separate too. For many in-scope groups that date is 30 November 2026, and it applies even to a small UAE entity inside a large global group.

Deregistration is not a clean exit

A group leaving scope cannot simply stop. Under FTA Decision No. 12 of 2026, an entity cannot be deregistered until all Top-up Tax and penalties are paid and all returns, including the Top-up Tax Return and the Pillar Two Information Return, are filed. So exiting the tax is a deliberate, complete process, not a lapse. There is also relief in the mechanics: a Domestic Designated Filing Entity can handle registration, deregistration, and notifications on behalf of all members of its group.

What to do about it

If your business is part of a multinational group approaching or above the EUR 750 million revenue mark, establish now whether any UAE entity is in scope of the Top-up Tax, and if so, find its registration deadline under FTA Decision No. 12 of 2026. For many the date is 30 November 2026. Where the group is genuinely out of scope, check whether an out-of-scope notification is needed. This is a specialist area with hard deadlines, and the businesses caught out are the local entities of global groups that assumed the ordinary Corporate Tax was the whole story.

This article is general information and is not tax advice. The Top-up Tax is governed by Cabinet Decision No. 142 of 2024 and FTA Decision No. 12 of 2026, which should be confirmed against their current text. We would be glad to assess whether your group is in scope and help you register on time.

/ FW GLOBAL CONSULTING

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