Top-Up Tax Registration UAE requirement is now mandatory under Cabinet Decision No. 142 of 2024 and Federal Tax Authority (FTA) Decision No. 12 of 2026. These rules set clear deadlines for when Multinational Enterprise (MNE) Groups must register, deregister, and notify the FTA under the UAE’s Global Minimum Tax system. The Decision applies to fiscal years starting on or after 1 January 2025.
This article explains the registration timelines, deregistration rules, notification requirements, the five-year out-of-scope period, and the role of the Domestic Designated Filing Entity.
Also check: Corporate Tax Services in UAE
What Does FTA Decision No. 12 of 2026 Require?
FTA Decision No. 12 of 2026 sets the operational rules for how entities must register and deregister under the UAE’s Top-Up Tax system. It also explains when entities must submit In-Scope Notification and Out-of-Scope Notification forms.
These rules apply to any entity that is part of an MNE Group in UAE with consolidated revenues of at least EUR 750 million under Pillar Two.
When Must an Entity Register: Top-Up Tax Registration Deadline
Seven-Month Registration Deadline
Entities that become in-scope for the first time must register within seven months from the end of that fiscal year. This is the main registration rule.
Special Deadline: 30 November 2026
If the fiscal year ends before 30 April 2026, the entity must register no later than 30 November 2026. This is a fixed date and an exception of the seven-month rule.
Below are examples that show how the deadlines work in practice:
- Fiscal year ends on 31 December 2025: Businesses must register by 31 July 2026
- Fiscal year ends on 31 March 2026: Businesses must register by 30 November 2026
- Fiscal year ends on 30 June 2026: Businesses must register by 31 January 2027
Need Expert Advice?
Contact the team at Farahat & Co. for professional support and expert insights for businesses operating in the UAE.
What Are the Top-Up Tax Deregistration Rules in the UAE?
According to FTA Decision No. 12 of 2026, entities must deregister within six months from the earliest of:
1. The Date the Entity Stops Existing
If the entity is liquidated or dissolved, deregistration must be done within six months.
2. The End of the Fiscal Year in Which the Entity Leaves the MNE Group
If the entity becomes out-of-scope, it must deregister within six months.
Special Deadline: 31 December 2026
If the entity stops existing before 30 June 2026, it must deregister by 31 December 2026.
Important Condition Before Deregistration
An entity cannot deregister until:
- All UAE Top-Up Tax is paid
- All penalties are paid
- All Top-Up Tax Returns are filed
- All Pillar Two Information Returns are filed
This ensures the entity has no outstanding obligations.
See also: Corporate Tax Consultant
When Must an Entity Submit an Out-of-Scope Notification?
If an MNE Group becomes out-of-scope for a fiscal year, the entity must submit an out-of-scope notification within six months from the end of that fiscal year.
This tells the FTA that the group does not meet the Pillar Two threshold for that year.
Validity Period: Five Fiscal Years
An out-of-scope notification stays valid for:
- The tested fiscal year
- The next four fiscal years
No repeated notifications are needed during this period.
When Must an Entity Submit an In-Scope Notification?
If the entity becomes in-scope again during the validity period, it must submit an in-scope notification within seven months from the end of the fiscal year.
This ensures the FTA is updated when the group re-enters the Pillar Two system.
Mandatory Deregistration After Five Out-of-Scope Years
If an entity stays out-of-scope for five consecutive fiscal years, it must deregister within six months, unless it becomes in-scope again.
This prevents inactive registrations from remaining in the system.
Who Files on Behalf of the Group?
If the group appoints a domestic designated filing entity, this entity handles all filings on behalf of the UAE group. It submits:
- Registration applications
- Deregistration applications
- In-scope notifications
- Out-of-scope notifications
It files for all UAE members of:
- Domestic Main Group
- Domestic Minority-Owned Subgroup
- Reverse Hybrid Entity
- Domestic JV Group
This makes compliance easier and consistent.
How the Deadlines Work?
An entity becomes in-scope for the first time in the fiscal year ending 31 December 2025.
- Registration deadline is 31 July 2026
- Leaves the MNE Group in fiscal year ending 31 December 2027: deregister by 30 June 2028
- Out-of-scope from 2027 to 2031: deregister by 30 June 2033
This shows how the seven-month and six-month rules apply step by step.
Practical Steps for MNE Groups to Stay Compliant
- Track fiscal year-end dates: All deadlines depend on fiscal year timing.
- Identify when you become in-scope: Check revenue thresholds and group structure.
- Prepare registration early: Do not wait until the last month.
- Monitor group changes: Leaving an MNE Group triggers deregistration.
- Keep compliance records updated: Returns and payments must be completed before deregistration.
- Use a Domestic Designated Filing Entity: This reduces administrative work and avoids missed deadlines.
Frequently Asked Questions (FAQs)
What is the main registration deadline?
What is the 30 November 2026 deadline?
When must an entity deregister?
How long does an out-of-scope notification stay valid?
What does a Domestic Designated Filing Entity do?
Need Expert Advice?
Contact the team at Farahat & Co. for professional support and expert insights for businesses operating in the UAE.
How Farahat & Co. Can Help
Farahat & Co. supports MNE Groups with full compliance under FTA Decision No. 12 of 2026 and the UAE’s Global Minimum Tax rules. We help you understand when entities become in-scope or out-of-scope, prepare and submit Top-Up Tax registration in UAE, manage Top-Up Tax deregistration in UAE, handle all notifications, review fiscal year deadlines, complete Top-Up Tax Returns and Pillar Two information returns, and ensure all tax and penalty obligations are settled before deregistration.
Contact Farahat & Co. today to make the process simple, clear, and fully compliant.
