Brief
UAE Federal Tax Authority publishes detailed guide on multinational top‑up tax
The guide explains how multinational enterprise groups are assessed under the QDMTT legislation and links to OECD Pillar Two rules.
By Felo News Desk · Published
The Federal Tax Authority (FTA) released a comprehensive Top‑up Tax Guide on 7 October, detailing how Multinational Enterprise (MNE) groups determine whether they fall within the scope of the Qualified Domestic Minimum Top‑up Tax (QDMTT) and what registration steps are required.
What happened
The guide outlines conditions for MNE groups to be in scope, identifies which entities are subject to the tax, and describes the registration process, timelines and filing of the Pillar Two Information Return. It covers permanent establishments, joint ventures, flow‑through and hybrid entities, and clarifies the treatment of entities based on location.
What the report adds
According to Gulf News, the QDMTT applies to constituent entities located in the UAE that belong to an MNE group with annual revenue of €750 million or more. The legislation, effective for fiscal years starting on or after 1 January 2025, aligns the UAE with the OECD/G20 Two‑Pillar Solution, specifically the Global Anti‑Base Erosion (GloBE) Model Rules under Pillar Two, which aim for a minimum effective tax rate of 15 % in each jurisdiction.
What was said
The FTA’s release states the guide is intended for tax‑affairs managers and tax agents handling MNE‑group responsibilities. It also notes the UAE’s “transitional qualified” status in the OECD central record as of 18 August 2025.
How it came about
The guide follows the UAE’s earlier corporate‑tax filing reminder on 26 September, which urged businesses to submit 2025 returns via the EmaraTax platform. Both pieces reflect the FTA’s broader effort to implement the OECD‑backed tax framework and preserve the UAE’s primary taxing right over domestic profits.
Key facts
- The FTA guide defines scope, registration and filing requirements for the Qualified Domestic Minimum Top‑up Tax. (gulfnews.com)
- The QDMTT applies to UAE entities in MNE groups with annual revenue of €750 million or more. (gulfnews.com)
- The legislation aligns with OECD/G20 Pillar Two and the GloBE Model Rules, targeting a 15 % minimum effective tax rate. (gulfnews.com)
Timeline
- 2025-08-18 — UAE listed with "transitional qualified" status in OECD central record
- 2026-09-26 — FTA reminder for 2025 corporate‑tax filing deadline
- 2026-10-07 — FTA publishes Top‑up Tax Guide
Sources
- [1] gulfnews.com — originally reported as “UAE Federal Tax Authority Releases Comprehensive Guide on Multinational Enterprise Top-Up Tax”
