The United Arab Emirates has introduced a 15% Domestic Minimum Top-up Tax (DMTT) for large multinational enterprise groups as part of the implementation of the OECD’s global Pillar Two initiative. The DMTT is intended to ensure that large multinational groups pay an effective tax rate of at least 15% on their profits.
While the obligation to register and deregister for DMTT already existed under the UAE framework, the Federal Tax Authority (FTA) had not previously prescribed the specific timelines for completing these processes.
FTA Decision No. 12 of 2026 now establishes the registration and deregistration deadlines applicable to entities within the scope of the UAE DMTT regime. The Decision applies to fiscal years beginning on or after 1 January 2025 and operates under Cabinet Decision No. 142 of 2024.
The Decision also introduces transitional deadlines for entities whose relevant fiscal years ended before the new general timelines would otherwise apply. In addition, it establishes an out-of-scope and in-scope notification mechanism designed to reduce repeated registration and deregistration requirements where an MNE group’s revenue fluctuates around the EUR 750 million threshold.
For businesses affected by the UAE DMTT, these timelines add an important compliance layer to the broader Pillar Two framework.
Introduction & Summary of Key Provisions
The UAE DMTT applies to large multinational enterprise groups and forms part of the UAE’s implementation of the OECD’s global Pillar Two framework.
FTA Decision No. 12 of 2026 provides practical timelines for:
- Tax registration
- Tax deregistration
- Out-of-scope notifications
- In-scope notifications following a return to the DMTT regime
- Deregistration following an extended period outside the scope of DMTT
The key deadlines are:
| Article | Topic | Key Provision | Deadline |
|---|---|---|---|
| Art. 2.1 | Tax Registration – General Rule | Entity must submit a Tax Registration application within 7 months from the end of the first Fiscal Year in which it falls in scope. | 7 months from FY-end |
| Art. 2.2 | Tax Registration – Transitional Rule | Entities with a Fiscal Year ending before 30 April 2026 must register regardless of the general 7-month rule. | 30 November 2026 |
| Art. 3.1 | Tax Deregistration – General Rule | Apply within 6 months from the earlier of cessation of existence or the FY-end in which the entity leaves the MNE Group and falls out of scope. | 6 months from trigger event |
| Art. 3.2 | Tax Deregistration – Transitional Rule | Entities ceasing to exist before 30 June 2026 must deregister under the transitional rule. | 31 December 2026 |
| Art. 4.1 | Out-of-Scope Notification | Where an MNE Group ceases to be in scope for a tested FY, the entities must notify the FTA. | 6 months from tested FY-end |
| Art. 4.3 | In-Scope Notification | If the Group re-enters scope during the five-year window, entities must notify the FTA again. | 7 months from tested FY-end |
| Art. 4.4 | Deregistration after Extended Out-of-Scope Period | If the group remains out of scope for five consecutive years, the entity must apply for deregistration. | 6 months from end of 5th consecutive FY |
These timelines provide greater clarity around the administrative obligations associated with the DMTT regime.
Tax Registration – General Rule
Under Article 2.1, an entity that falls within the scope of the UAE DMTT must submit its Tax Registration application within 7 months from the end of the first Fiscal Year in which it falls in scope.
The deadline is therefore linked to the end of the relevant fiscal year rather than being a fixed calendar date applicable to every entity.
For MNE groups entering the UAE DMTT regime for the first time, determining the first fiscal year in which the group falls within scope will therefore be an important step in establishing the registration deadline.
Tax Registration – Transitional Rule
FTA Decision No. 12 of 2026 also provides a transitional rule.
Entities with a Fiscal Year ending before 30 April 2026 must register under the transitional provision, regardless of the general seven-month registration timeline.
The applicable transitional deadline is:
30 November 2026
This provision is particularly relevant for entities whose first in-scope fiscal year has already ended or is ending before the general registration timeline would otherwise provide a deadline.
Businesses within this category should assess their DMTT status and registration position well before the transitional deadline.
Tax Deregistration – General Rule
The Decision also establishes the timeline for entities that need to deregister from the DMTT regime.
Under Article 3.1, an entity must apply for deregistration within 6 months from the earlier of:
- The date on which the entity ceases to exist; or
- The end of the Fiscal Year in which the entity leaves the MNE Group and falls outside the scope of the DMTT.
This creates two potential trigger events for deregistration.
The relevant six-month period therefore needs to be assessed based on the circumstances that cause the entity to cease being subject to the DMTT registration requirement.
Tax Deregistration – Transitional Rule
A separate transitional rule applies to entities that ceased to exist before 30 June 2026.
Such entities must deregister under the transitional provision, with the applicable deadline being:
31 December 2026
The transitional deadline applies regardless of the general six-month rule.
The Decision also makes clear that the transitional provisions do not remove the other compliance requirements associated with deregistration. Entities must settle outstanding obligations and complete the required filings before deregistration can be approved.
Out-of-Scope Notification
The Decision introduces an important mechanism for MNE groups that cease to fall within the DMTT regime.
Where an MNE Group ceases to be in scope for a tested Fiscal Year, the relevant entities must notify the FTA.
The notification must be submitted within 6 months from the end of the tested Fiscal Year.
Importantly, the notification remains valid for the tested Fiscal Year plus the next four consecutive Fiscal Years, resulting in a total five-year period, unless the MNE Group re-enters the scope of the DMTT during that period.
This mechanism is intended to avoid unnecessary cycles of registration and deregistration where an MNE group’s revenue fluctuates around the EUR 750 million threshold from year to year.
Instead of requiring entities to repeatedly register and deregister each time the group moves above or below the relevant threshold, the out-of-scope notification can remain effective for the five-year period, subject to the group re-entering the scope.
In-Scope Notification
The five-year out-of-scope mechanism does not mean that an entity can remain outside the compliance framework if the MNE Group subsequently returns to scope.
Where the group re-enters the DMTT scope during the five-year notification window, the entities must notify the FTA again.
The applicable deadline is 7 months from the end of the tested Fiscal Year in which the group re-enters scope.
This creates a clear distinction between the initial out-of-scope notification and the subsequent obligation to notify the FTA when the group again becomes subject to the DMTT regime.
Deregistration after Extended Out-of-Scope Period
If an out-of-scope notification remains valid for the full five consecutive Fiscal Years and the MNE Group does not return to the DMTT regime during that period, the entity must then apply for deregistration.
The deregistration application must be made within 6 months from the end of the fifth consecutive Fiscal Year.
This provides a structured process for entities that remain outside the DMTT scope over an extended period.
The mechanism can therefore be viewed as a sequence:
Out-of-scope notification → Five-year validity period → No return to scope → Deregistration
If the group returns to scope at any point during those five years, the entity instead moves back into the in-scope notification process.
Notes
Settlement of Tax and Filing Obligations Before Deregistration
Deregistration will not be approved unless all Top-up Tax and penalties are settled in full and the Top-up Tax Return and Pillar Two Information Return have been filed.
This means that deregistration should not be treated as a process that independently closes the entity’s outstanding DMTT compliance obligations.
Entities seeking deregistration should first ensure that their outstanding tax liabilities, penalties and required filings have been addressed.
Transitional Deadlines
The transitional registration deadline of 30 November 2026 and deregistration deadline of 31 December 2026 apply broadly to entities whose first in-scope Fiscal Year ended, or which ceased to exist, in 2025 or early-to-mid 2026.
The requirement to settle outstanding dues and file required returns before deregistration also applies to these entities.
Avoiding Repeated Registration and Deregistration
The out-of-scope and in-scope notification mechanism provides an important compliance simplification for groups whose revenue fluctuates around the EUR 750 million threshold.
Instead of repeatedly moving between registration and deregistration as the group’s position changes from year to year, the out-of-scope notification remains valid for five years unless the group returns to scope.
Domestic Designated Filing Entity
A Domestic Designated Filing Entity may file registration, deregistration and scope notifications on behalf of all members of a:
- Domestic Main Group
- Domestic Minority-owned Subgroup
- Reverse Hybrid Entity
- Domestic JV Group
This can centralise the relevant administrative filings within the applicable domestic group structure.
DMTT Registration and Filing Deadlines Are Separate
It is important to distinguish the deadlines established by FTA Decision No. 12 of 2026 from the deadlines applicable to the Top-up Tax Return and Pillar Two Information Return (GIR).
The Decision governs the due dates for registration and deregistration.
The filing deadlines for the Top-up Tax Return and Pillar Two Information Return continue to be governed separately, with standard 15-month and 18-month transitional filing deadlines running on a separate timeline.
This distinction is important because the registration or deregistration deadline should not be assumed to be the same as the filing deadline for the DMTT returns.
What Businesses Should Consider
FTA Decision No. 12 of 2026 gives MNE groups clearer administrative deadlines under the UAE DMTT regime. For affected entities, the immediate priority should be determining which timeline applies to their specific circumstances.
Entities should consider:
First, determine the first Fiscal Year in which the entity falls within the DMTT scope. This establishes the starting point for assessing the general seven-month registration deadline.
Second, check whether the transitional registration deadline applies. Entities with a Fiscal Year ending before 30 April 2026 should assess the 30 November 2026 registration deadline.
Third, identify any event that triggers deregistration. This could be the date the entity ceases to exist or the end of the Fiscal Year in which it leaves the MNE Group and falls outside the DMTT scope.
Fourth, assess whether an out-of-scope notification is more appropriate than immediate deregistration. Where the group has ceased to be in scope but could potentially move back into scope, the five-year notification mechanism may be relevant.
Finally, distinguish administrative deadlines from return filing deadlines. The registration and deregistration timelines under Decision No. 12 of 2026 operate separately from the filing timelines for the Top-up Tax Return and Pillar Two Information Return.
Key Takeaway
FTA Decision No. 12 of 2026 brings greater certainty to the administrative side of the UAE’s Domestic Minimum Top-up Tax regime.
For entities falling within scope, the general registration deadline is 7 months from the end of the first in-scope Fiscal Year. For deregistration, the general deadline is 6 months from the applicable trigger event.
The transitional rules create two important 2026 deadlines:
- 30 November 2026 for applicable transitional registrations
- 31 December 2026 for applicable transitional deregistrations
The Decision also provides a five-year out-of-scope notification mechanism that can reduce repeated registration and deregistration requirements where an MNE group’s position changes around the EUR 750 million threshold.
At the same time, entities should remember that deregistration is conditional on settling outstanding Top-up Tax and penalties and completing the required filings.
For MNE groups operating in the UAE, the practical message is clear: DMTT compliance now requires not only determining whether the group is in scope, but also tracking the specific registration, notification and deregistration deadlines that follow from that determination.
FAQs
What is UAE Domestic Minimum Top-up Tax?
The UAE Domestic Minimum Top-up Tax, or DMTT, is a 15% minimum tax applicable to large multinational enterprise groups as part of the UAE’s implementation of the OECD’s global Pillar Two initiative.
When must an entity register for UAE DMTT?
Under the general rule, an entity must submit its Tax Registration application within 7 months from the end of the first Fiscal Year in which it falls within scope.
What is the transitional DMTT registration deadline?
Entities with a Fiscal Year ending before 30 April 2026 must register under the transitional rule by 30 November 2026.
When must an entity deregister from UAE DMTT?
An entity must generally apply for deregistration within 6 months from the earlier of the date it ceases to exist or the end of the Fiscal Year in which it leaves the MNE Group and falls out of scope.
What is the transitional deregistration deadline?
Entities that ceased to exist before 30 June 2026 are subject to the transitional deregistration deadline of 31 December 2026.
What happens when an MNE Group goes out of scope?
The relevant entities must notify the FTA within 6 months from the end of the tested Fiscal Year. The notification remains valid for that Fiscal Year and the following four consecutive Fiscal Years, unless the group re-enters scope.
What happens if the MNE Group comes back into scope?
If the group re-enters the DMTT scope during the five-year out-of-scope notification period, the entities must notify the FTA again within 7 months from the end of the tested Fiscal Year.
When is deregistration required after remaining out of scope?
If the group remains out of scope for the full five consecutive Fiscal Years without returning to scope, the entity must apply for deregistration within 6 months from the end of the fifth consecutive Fiscal Year.
Can an entity deregister if it has outstanding DMTT liabilities?
No. Deregistration will not be approved unless all Top-up Tax and penalties are settled in full and the required Top-up Tax Return and Pillar Two Information Return have been filed.
Are the DMTT registration deadlines the same as the DMTT return filing deadlines?
No. FTA Decision No. 12 of 2026 deals with registration and deregistration timelines. The Top-up Tax Return and Pillar Two Information Return have separate filing deadlines of 15 months, or 18 months during the transitional period.
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Disclaimer: This article is intended for general guidance only and should not be considered as an advice or opinion. On any specific matter, reference should be made to the appropriate advisor.
