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The UAE Federal Tax Authority’s August 2026 Scope and Registration guide explains which multinational groups may fall under the country’s qualified domestic minimum top-up tax (QDMTT), part of the OECD/G20 Pillar Two framework. Emirates News Agency reported on the guide’s scope and registration provisions on 7 October; the FTA’s official PDF itself is dated August 2026. Under the rule, a group’s consolidated annual revenue must be at least EUR750 million in at least two of the four fiscal years immediately before the fiscal year being tested. The threshold is based on revenue in consolidated financial statements at group level.
The guide says groups operating exclusively within the UAE do not fall within the QDMTT legislation even if their revenue exceeds the threshold. The rules apply to in-scope constituent entities located in the UAE that belong to a qualifying multinational group; an entity’s location and role in the group also affect the analysis. Crossing the revenue test does not by itself mean every subsidiary owes top-up tax. The guide provides detailed explanations and examples for structures including parent entities, permanent establishments, joint ventures, hybrid entities and flow-through entities.
The first fiscal years covered begin on or after 1 January 2025. Under the FTA guide, an entity whose fiscal year ends before 30 April 2026 should apply to register by 30 November 2026; in other cases, registration is due within seven months after the end of the first fiscal year in which the entity is in scope. The guide states that late registration carries an administrative penalty of AED10,000 per entity. The applicable deadline depends on an entity’s fiscal-year calendar and specific group circumstances, so the date is not a single filing obligation for every company.
The guide operationalises scope and compliance obligations rather than announcing a change to the tax rate. The global minimum rate under Pillar Two does not guarantee the same tax calculation in every country or a 15% top-up payment for every company. Scope and effective-tax-rate calculations depend on details such as exclusions, credits and entity structure; the guide points readers to the governing legislation and implementing decisions. A practical first step for companies is to test consolidated revenue over the four-year window, identify UAE constituent entities and align registration dates with fiscal-year ends. This report summarises the general framework and does not determine any particular group’s liability.


