The guide also explains how to register and how to file the regime's information return. It follows Ministerial Decision No. 133 of 2026 on the Pillar Two Information Return and concerns a narrow group of very large multinationals.
What happened
On 7 October 2026 the Federal Tax Authority (FTA, the UAE federal tax authority) announced the Top-up Tax Guide on Scope and Registration. The Top-up Tax is the domestic minimum top-up tax through which the UAE applies Pillar Two, the global minimum tax framework agreed under the OECD (the Organisation for Economic Co-operation and Development), to multinational groups. According to the announcement, the guide explains when a group falls within the regime, which entities are subject to it, how permanent establishments, joint ventures, flow-through entities and hybrid entities are treated, how to register, and how to file the Pillar Two Information Return, the regime's information return. The full text is on the FTA website.
What changes in practice
The law itself is unchanged: what changes is that the official interpretation now sits in a single document. The regime applies to fiscal years beginning on or after 1 January 2025. The entry test, the list of entities inside and outside the perimeter and the registration route were previously spread across the legislation and its implementing decisions, including Ministerial Decision No. 133 of 2026. The registration and filing deadlines are not in the announcement and need to be read in the guide itself.
Who it applies to
UAE-located entities that belong to a multinational group with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding fiscal years, as shown in the ultimate parent's consolidated financial statements. A group that operates only in the UAE is outside the regime, whatever its revenue. A company that is not part of a group above the threshold is therefore not affected. Where a company is part of such a group, it should not assume that the parent will deal with it: Decision No. 133 already indicates that the filing obligation can fall on entities located in the UAE.
The exposure
The exposure comes from a wrong assumption in either direction. A group above the threshold that assumes the parent will register and file may find that a UAE entity has not been registered. A company below the threshold that registers or files without being obliged to do so incurs unnecessary cost. The most delicate cases are joint ventures and hybrid structures, which the guide treats separately and where the perimeter is not intuitive. The consequences of failing to register or file are not set out in the announcement and should not be assumed.
What to do now
First, take the revenue of the last four fiscal years from the parent's consolidated financial statements and test it against the EUR 750 million threshold. Second, if the group is above it, list every UAE entity, including permanent establishments and joint ventures. Third, download the guide from the FTA website and read the chapters on registration and filing, which contain the deadlines. Fourth, agree in writing with the parent who registers and who files, entity by entity. If the company is below the threshold, record the test and its date in the compliance file.
Sources
Published 11 October 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.