New Registration and Deregistration Requirements in 2026 for Multinational Enterprises
The UAE Federal Tax Authority (FTA) has issued Federal Tax Authority Decision No. 12 of 2026, setting out specific requirements for the registration, deregistration and in-scope/out-of-scope notifications of entities subject to the UAE’s Top-Up Tax regime for multinational enterprises (MNEs).
The Decision applies to Fiscal Years beginning on or after 1 January 2025 and provides important compliance deadlines for businesses within the scope of the UAE’s implementation of the OECD’s Pillar Two rules.
Important: This article is based on the FTA’s unofficial English translation of Decision No. 12 of 2026 and is provided for general information. It should not be treated as official legal or tax advice.
Who Does the Decision Apply To?
The Decision is relevant to entities that fall within the scope of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
The rules are particularly relevant to UAE entities that are members of an MNE Group falling within the applicable Pillar Two scope.
Businesses should therefore assess their group structure, consolidated revenue and UAE presence before determining whether registration or notification requirements apply.
Top-Up Tax Registration Deadline
An entity that is subject to Top-Up Tax must submit a Tax Registration application for Top-Up Tax purposes within seven months from the end of the first Fiscal Year in which it becomes in scope.
However, the FTA has established a specific transitional deadline:
Fiscal Years ending before 30 April 2026
Where an entity’s Fiscal Year ends before 30 April 2026, its Top-Up Tax registration application must be submitted on or before 30 November 2026.
This makes 30 November 2026 an important compliance date for affected UAE entities.
Deregistration From Top-Up Tax
An entity may need to deregister where it:
- Ceases to exist; or
- Leaves an MNE Group and is no longer within the scope of the UAE Top-Up Tax rules.
Generally, the deregistration application must be submitted within six months from the relevant date.
A special transitional rule applies where an entity ceased to exist before 30 June 2026. In such cases, the deregistration application must be submitted on or before 31 December 2026.
Deregistration Is Not Automatic
Before deregistration can be approved, the entity must have:
- Settled all Top-Up Tax and applicable penalties;
- Filed all required Top-Up Tax Returns; and
- Filed all required Pillar Two Information Returns.
The FTA may also deregister an entity where it meets the applicable requirements but has not submitted a deregistration application, based on information available to the Authority.
Out-of-Scope Notification
An entity that is a member of an MNE Group but whose group is no longer within the applicable scope for a tested Fiscal Year must submit an out-of-scope notification within six months from the end of that Fiscal Year.
An approved out-of-scope notification generally remains valid for:
The tested Fiscal Year + four consecutive Fiscal Years
This means businesses should not assume that an out-of-scope position is permanent. Their status must continue to be monitored.
What Happens if the Group Becomes In-Scope Again?
If an entity becomes in scope in a subsequent Fiscal Year while its previous out-of-scope notification remains valid, it must submit an in-scope notification within seven months from the end of the tested Fiscal Year.
This creates an ongoing monitoring requirement for MNE groups whose status changes from year to year.
Five Consecutive Years Out of Scope
Where an out-of-scope notification remains valid for five consecutive Fiscal Years, the entity must generally submit a Top-Up Tax deregistration application within six months from the end of the fifth consecutive Fiscal Year, unless it becomes subject to an in-scope notification requirement.
This provides a mechanism for entities that remain outside the regime for an extended period to formally exit the Top-Up Tax registration framework.
Domestic Designated Filing Entity
The Decision also addresses situations where a Domestic Designated Filing Entity has been appointed.
In such cases, the designated entity may submit the relevant:
- Tax Registration application;
- Tax Deregistration application;
- In-scope notification; or
- Out-of-scope notification
on behalf of the relevant members of a Domestic Main Group, Domestic Minority-owned Subgroup, Reverse Hybrid Entity or Domestic JV Group, as applicable.
This can centralise certain compliance activities within the UAE group structure.
Key Deadlines at a Glance
| Requirement | Deadline |
|---|---|
| Top-Up Tax registration | Within 7 months after the end of the first in-scope Fiscal Year |
| Fiscal Year ending before 30 April 2026 | Registration by 30 November 2026 |
| Deregistration | Within 6 months of the relevant triggering event |
| Entity ceased to exist before 30 June 2026 | Deregistration by 31 December 2026 |
| Out-of-scope notification | Within 6 months after the end of the tested Fiscal Year |
| In-scope notification after previous out-of-scope status | Within 7 months after the end of the tested Fiscal Year |
| Five consecutive years out of scope | Deregistration within 6 months after the fifth Fiscal Year |
What Should UAE Businesses Do Now?
MNE groups with UAE entities should consider undertaking a structured Pillar Two compliance assessment covering:
- Group scope – determine whether the MNE Group falls within the applicable Top-Up Tax regime.
- Fiscal year – identify the relevant Fiscal Year and applicable registration deadline.
- Entity structure – map UAE entities, JVs and relevant group relationships.
- Registration status – determine whether Top-Up Tax registration is required.
- In-scope/out-of-scope status – establish whether a notification is required.
- Filing responsibilities – identify whether a Domestic Designated Filing Entity applies.
- Data readiness – assess whether financial and tax data required for Pillar Two calculations and reporting is available.
- Compliance calendar – establish controls to monitor registration, notification and filing deadlines.
Crossfoot Advisory Perspective
The UAE’s Top-Up Tax regime introduces an additional layer of international tax compliance for qualifying multinational groups. The new FTA Decision provides greater clarity around the administrative obligations and deadlines, but businesses should first establish whether they are actually within the scope of the underlying Pillar Two rules.
For multinational groups operating through multiple UAE entities, the assessment should be approached as a group-level tax and compliance exercise, rather than simply an entity-level registration task.
Crossfoot Advisory, Dubai, supports businesses and international investors with UAE Corporate Tax, VAT, international tax planning, cross-border transactions, financial structuring and tax compliance advisory.
For businesses potentially affected by the UAE Top-Up Tax regime, an early assessment can help identify registration obligations, reporting requirements and data gaps before statutory deadlines arise.
Regulatory Reference
Federal Tax Authority Decision No. 12 of 2026 – Requirements for Registration and Deregistration of Entities for the purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
Issued: 16 July 2026
Applicable: Fiscal Years starting on or after 1 January 2025
This article is based on the unofficial English translation provided for the FTA Decision and is intended for general informational purposes only. It does not constitute tax, legal or professional advice. Businesses should review the official legislation and obtain appropriate professional advice based on their specific circumstances.
