Pillar Two Registration & Compliance

UAE| OECD PILLAR TWO

Federal Tax Authority (FTA) decision no 12— DMTT effective for fiscal years beginning on or after 1 January 2025

GLOBAL MINIMUM TAX

Background – Pillar Two

UAE had officially implemented OECD Pillar Two Global Minimum Tax framework, effective for fiscal years beginning on or after 1 January 2025, introducing the Domestic Minimum Top-Up Tax (DMTT)

FTA opened the portal for Pillar Two registration in June 2026 however the compliance timeline for registration was awaited

Recently, FTA released a decision¹ covering compliance timelines for registration, deregistration, and in scope & out scope notification

This is applicable from Fiscal year beginning on or after 1^st January 2025

Registration & Deregistration

Registration

Timeline: For FY ending before 30^th April 2026 Registration application should be submitted by 30^th November 2026

For FY ending on or after 30^th April 2026, Registration application should be submitted within 7 months from the end of the fiscal year in which entity becomes in scope of pillar two regulations

Process: Entities can register individually or appoint a Designated Domestic filling entity to register on behalf of all in-scope entities in the group

DDFE can register on behalf of subsidiaries, PEs, minority owned sub-groups and Reverse Hybrid entities whereas JV Group requires separate registration and can appoint a member of the JV group as the DDFE

Deregistration

Applicability: Applicable when an entity ceases to exist or when entity stops being an in-scope member of the MNE Group.

Timeline – for entities ceasing to exist

Approval: Contingent on settling all tax payables and penalties relating to top up tax and filing of all top up tax returns and GIR return

DDFE: In case entity has nominated a DDFE, Deregistration application is to be filed by DDFE

In-scope & Out of scope notification

Out of Scope notification

Required if MNE Group ceases to be in-scope (i.e., is below the threshold for Pillar Two)

When: 6 months from the end of tested Fiscal year where MNE Group is out of scope- Valid for tested fiscal year and subsequent 4 years. If out of scope at the end of fifth year, to be renewed within 6 month from the end of fifth year.

In Scope notification

Required if the MNE becomes in-scope within 4 years of filing of an out of scope notification

When: 7 month from the end of tested Fiscal year where MNE Group is in scope

Readiness & Next Steps

Assess Now to Avoid Tax and Penalty Risk

Assess Scope

Confirm whether the Group meets the EUR 750M+ Pillar Two threshold and identify the Designated Local Entity.

Strengthen Governance

Build a Pillar Two governance framework covering registration, filing, and audit-readiness responsibilities.

Prepare Data & Documentation

Get records, books, and supporting documentation audit-ready to avoid record-keeping penalties.

Review Filing Responsibilities

Map out registration timelines and DMTT filing well ahead of time.

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