UAE Opens Pillar Two Registration as Global Minimum Tax Compliance Enters a New Phase

The UAE Federal Tax Authority has opened Pillar Two top-up tax registration on the EmaraTax portal. This activates the 15% Domestic Minimum Top-up Tax introduced under Cabinet Decision No. 142 of 2024. Middle East Briefing reported the launch.

Registration moves the rules from statute into administration. The compliance cycle for the first fiscal year has already begun.

Scope is assessed at group level. Multinational groups with EUR 750 million in revenue across two of the prior four years are captured. Free zone entities on a 0% rate are not exempt. A UAE subsidiary with modest local revenue still qualifies if the wider group crosses the line.

In-scope groups now face a decision. Appoint one Domestic Designated Filing Entity, or register each entity separately.

Authorizations for the designated entity lapse after 14 business days.

First returns fall due within 15 months of period end, extended to 18 for the transitional year.

GloBE calculations can run to several hundred data points per entity.

The FTA has not set a registration deadline. That is not a reason to wait. Entity mapping, governance choices, and data readiness are current-year work.

Is your group structure documented for this, or is it still a 2027 problem?