The United Arab Emirates (UAE) Federal Tax Authority (FTA) has now activated the Pillar Two Top-up Tax registration functionality through the EmaraTax portal. In-scope Multinational Enterprise (MNE) Groups should begin assessing their registration obligations and gathering the required information and documentation.
While the registration portal is operational, the FTA has not yet issued detailed guidance regarding the registration deadline, filing timelines, administrative procedures, or penalty framework. Further guidance from the FTA is therefore expected. Considering the limited guidance currently available, entities may wish to wait for further clarification from the FTA before completing the registration process, particularly where additional guidance could impact the information required or the registration approach. Larger groups may also wish to consider a coordinated approach to registration to help manage duplicate or unnecessary registrations.
Below we have highlighted key insights from the registration form.
Scope — Who must register?
Entities must register if they are a member of an MNE Group where:
- Annual revenue is EUR 750 million or more in the Consolidated Financial Statements of the Ultimate Parent Entity (UPE) for at least two of the four fiscal years immediately preceding the tested fiscal year; or
- The entity is in scope of Pillar Two Top-up Tax due to a merger, acquisition, or demerger.
As part of the assessment, groups should also evaluate whether any UAE Permanent Establishments (PEs), Joint Ventures (JV), flow-through entities, or other Constituent Entities fall within the scope of the UAE Pillar Two rules and require inclusion in the registration process.
Two Registration Routes (via EmaraTax)
Route 1 — Domestic Designated Filing Entity (DDFE)A DDFE is a Constituent Entity that files the Top-up Tax Return and pays the Top-up Tax on behalf of all members of a Domestic Main Group, Domestic Minority-owned Subgroup, Reverse Hybrid Entity, or Domestic JV Group. The DDFE is authorised to perform all applicable tax administrative functions in EmaraTax for the relevant group.
Route 2 — Individual Entity Registration
An entity can only register individually if the relevant group does not have a DDFE. Where a DDFE is appointed, the DDFE will generally coordinate the registration process and administrative obligations through EmaraTax on behalf of eligible UAE group members. Groups should evaluate whether a DDFE approach is appropriate before initiating registrations.
Information Required at Registration
Particular attention should be given to identifying all UAE Constituent Entities and PEs, as PE information is specifically requested during the registration process. Groups should ensure consistency between registration information, legal ownership structures, and Pillar Two calculations.
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Section
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Information required
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MNE group
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Name of MNE Group; start and end date of first Reporting Fiscal Year; whether part of a Multi-Parented MNE Group; Ultimate Parent Entity name, jurisdiction, and TIN
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Entity details
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Tax Identification Number and name of the entity; whether the entity is a PE, Excluded Entity, or Investment Entity, whether a Designated Local Entity is to be appointed
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Domestic Group Members (DDFE only)
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Details of all domestic group entities, which can be entered manually or via a downloadable Excel template
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Authorised signatory
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Name (English and Arabic), ID number, and email address of the authorised signatory
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Documents required
- Corporate structure overview — Supporting document(s) providing an overview of the entire corporate structure of the MNE group, including the Controlling Interests that any Group Entity has in any other Entity of the same Group, including entities located both inside and outside the UAE (max 5 files; max 15 MB each; DOC, DOCX, or PDF format).
- Letter of authorisation (DDFE route) — An authorisation letter from all entities that are part of the relevant group, nominating the DDFE to act on their behalf.
- Member acknowledgement (DDFE route) — All entities nominating the DDFE must provide authorisation, either by the DDFE uploading supporting documents or by initiating separate acknowledgement requests through EmaraTax. Entities must respond within 14 business days, failing which the acknowledgement request will be automatically cancelled. The DDFE may only submit the completed registration after all entities have provided their authorisation.
- Additional supporting documents (Optional) — Additional documentary evidence to support the Pillar Two Top-up Tax registration application may be uploaded (max 5 files; max 15 MB each; DOC, DOCX, or PDF format).
Further Guidance:
The FTA is expected to issue additional guidance regarding registration deadlines, return filing obligations, payment procedures, notifications, administrative requirements and potential penalties. Registration should therefore be viewed as the first phase of the UAE Pillar Two compliance process rather than the completion of compliance obligations
Key Reminder:
- Entities that do not meet the applicable revenue threshold and are not in scope due to a merger, acquisition, or demerger cannot submit a Pillar Two Top-up Tax registration application.
- The EmaraTax registration functionality is now operational; however, the FTA has not yet announced the registration deadline or comprehensive compliance guidance. In-scope groups should begin registration readiness activities, identify all UAE Constituent Entities (including PEs), determine whether a DDFE approach is appropriate, and monitor further FTA announcements.