The Federal Tax Authority (FTA) has officially issued FTA Decision No. 12 of 2026, establishing critical guidelines and strict timelines regarding Registration, Deregistration, and Status Notifications under the UAE’s Domestic Minimum Top-Up Tax (DMTT) regime.
Formally issued in line with the UAE’s Global Anti-Base Erosion (GloBE) / Pillar Two rules under Cabinet Decision No. 142 of 2024, this decision applies to fiscal years beginning on or after 1 January 2025.
If your UAE entity is part of a Multinational Enterprise (MNE) group with annual consolidated group revenues exceeding EUR 750 million, understanding these compliance obligations and timelines is critical to avoiding non-compliance penalties.
Key Deadlines and Compliance Timelines
FTA Decision No. 12 of 2026 sets out specific windows within which affected UAE entities and constituent groups must complete their regulatory filings:
| Compliance Requirement | Timeline / Cutoff Date | Description |
| Standard Top-Up Tax Registration | Within 7 months | Must be submitted from the end of the first fiscal year in which the entity falls in scope of DMTT. |
| Transitional Registration Deadline | 30 November 2026 | Applies to entities with fiscal years ending before 30 April 2026 (e.g., standard December 31, 2025 year-ends). |
| Top-Up Tax Deregistration | Within 6 months | Must be filed from the date the entity ceases to be in scope or ceases operations (subject to settling all liabilities and returns). |
| In-Scope Notification | Within 7 months | Mandatory notification filing confirming group status following the end of the fiscal year. |
| Out-of-Scope Notification | Within 6 months | Filed when an entity’s status changes to out-of-scope following the end of the tax period. |
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Important Distinction: Corporate Tax vs. Top-Up Tax
A common misconception among business leaders is that standard UAE Corporate Tax registration covers all tax obligations.
Top-Up Tax registration is a separate regulatory filing. Even if your UAE entity is already registered for UAE Corporate Tax, you must complete a distinct Top-Up Tax registration process with the FTA if your group meets the Pillar Two criteria.
How Your Business Should Prepare
- Perform a Scope Assessment: Evaluate your global group revenue and local constituent entity structure to verify DMTT applicability.
- Review Fiscal Year End Dates: Determine whether your entity qualifies for the 30 November 2026 transitional registration deadline.
- Align Accounting Data: Ensure financial records and consolidated reporting meet GloBE / Pillar Two calculation standards.
- Engage Registered Tax Advisors: Partner with tax professionals early to streamline registration and manage required notifications seamlessly.
Partner with LEONARD DUMLAO & Associates
Navigating complex international tax frameworks requires clear strategy and precision. As a UAE Registered Tax Agency, LEONARD DUMLAO & Associates provides end-to-end support for Multinational Enterprise groups operating across the Emirates.
Our DMTT & Corporate Tax Services Include:
- Pillar Two & DMTT Scope Impact Assessments
- Top-Up Tax Registration & FTA Filings
- Comprehensive UAE Corporate Tax & VAT Compliance
- Strategic Tax Advisory & Accounting Support
Contact Our Advisory Team Today:
- 📞 Phone / WhatsApp: +971 50 506 1908
- 📧 Email: info@laafzllc.com
- 🌐 Website: www.laafzllc.com