Pillar Two in the UAE: registration deadlines set, information return rules in force

UAE entities of large multinational groups must register for the domestic minimum top-up tax within seven months of the end of their first in-scope fiscal year. That rule is in FTA Decision No. 12 of 2026 on Registration and Deregistration Timelines, issued on 16 July 2026 and published on 4 August 2026. Ministerial Decision No. 133 of 2026 on the Entities Required to File the Pillar Two Information Return was issued on 3 August 2026 and took effect on issue. In August 2026 the Federal Tax Authority published its Top-up Tax Guide on Scope and Registration (TTGREG1), which it announced on 7 October 2026. All of it bears on UAE entities of multinational groups with consolidated revenue of EUR 750 million or more.

What the rules say

Registration. An in-scope entity must submit a tax registration application "within a period not exceeding (7) seven months from the end of the first Fiscal Year in which the Entity is in scope" (Article 2(1) of FTA Decision No. 12 of 2026). A transitional rule follows: an entity whose fiscal year ends before 30 April 2026 must register on or before 30 November 2026 (Article 2(2)). A Domestic Designated Filing Entity submits the registration or deregistration application on behalf of all members of a Domestic Main Group, a Domestic Minority-owned Subgroup or a Domestic Joint Venture Group, or for a Reverse Hybrid Entity (Article 5). The decision applies to fiscal years starting on or after 1 January 2025. The FTA marks its English text as an unofficial translation; the Arabic text is the authoritative one.

The information return. Ministerial Decision No. 133 of 2026 is short. It uses the definitions in the Annexure to Cabinet Decision No. 142 of 2024 and applies to fiscal years starting on or after 1 January 2025 (Article 3).

What goes in the return is governed by Article 15 of the Annexure to Cabinet Decision No. 142 of 2024. The decision itself sets no filing deadline for the return.

Penalty. The FTA guide states, at Section 8.5, that "an Administrative Penalty of AED 10,000 will apply where an Entity fails to submit an application for registration within the relevant timeline". The penalty does not come from Decision No. 12. Its legal basis is Violation No. 14 of Cabinet Decision No. 75 of 2023, which Article 14.1(d) of Cabinet Decision No. 142 of 2024 applies to the top-up tax. If a Domestic Designated Filing Entity fails to register the members it represents, the guide says the penalty applies in respect of each entity.

Scope. The guide confirms the scope test. The top-up tax applies to UAE-located Constituent Entities of a group whose Ultimate Parent Entity's consolidated financial statements show annual revenue of EUR 750 million or more in at least two of the four fiscal years before the year being tested. A group that operates only in the UAE is out of scope, whatever its size. The guide also covers excluded entities, registration and timelines, permanent establishments, joint ventures, flow-through and hybrid entities, location rules and the information return.

Who is affected

UAE subsidiaries, permanent establishments and joint ventures of multinational groups that meet the EUR 750 million test. Neither the guide nor the FTA's announcement separates mainland from free zone entities. The only question is whether an entity is a UAE-located Constituent Entity of an in-scope group. If you have a free zone company paying corporate tax at 0 per cent, do not assume it sits outside the top-up tax.

Investment Entities do not have to file the information return under Decision No. 133 of 2026. If your group has funds or holding vehicles in the UAE, check how the guide treats them for the tax itself.

Key dates

What it means in practice

A calendar-year group's first in-scope year is 2025, so it registers under the transitional rule. Take a hypothetical European group with EUR 900 million revenue that owns a Dubai free zone distributor and an Abu Dhabi mainland services company. Both are UAE Constituent Entities. The group can appoint one of them as Domestic Designated Filing Entity and have it register both by 30 November 2026. Miss the date and the AED 10,000 penalty applies for each entity left unregistered. If the parent files the information return in a jurisdiction with a qualifying agreement with the UAE, the UAE entities only have to tell the FTA who filed and where.

The same logic reaches location decisions. Moving activity into a UAE free zone does not take a large group out of the minimum tax.

What we do not yet know

Decision No. 133 of 2026 does not set the filing date for the information return, and we could not confirm one on an official page. The FTA has not yet published a return-filing guide to sit alongside the registration guide.