Pillar Two registration now available in the UAE

Background

The Federal Tax Authority (FTA) has enabled Pillar Two Top-up Tax registration on the EmaraTax portal. UAE Constituent Entities of in-scope multinational enterprise (MNE) groups should consider initiating the registration process and preparing for compliance with the UAE’s Qualified Domestic Minimum Top-up Tax framework.

This development follows the UAE’s implementation of the OECD Global Anti-Base Erosion (GloBE) rules under Pillar Two, which apply to MNE groups with consolidated revenues of at least EUR 750 million in at least two of the four preceding financial years. The UAE rules are applicable for financial years starting on or after 1 January 2025.

 

Registration process

Registration for Pillar Two Top-up Tax is conducted through the EmaraTax portal. In-scope MNE groups may choose how their Pillar Two obligations will be managed within the UAE, either through a single designated entity or by individual entities acting independently.

Under the first approach, a UAE entity is appointed as the Domestic Designated Filing Entity (DDFE), taking responsibility for managing the Top-up Tax obligations on behalf of all UAE Constituent Entities within the group. Alternatively, where no such designation is made, each UAE Constituent Entity is required to register and manage its obligations itself.

The choice between these approaches should be carefully assessed, as it determines how compliance responsibilities are allocated across the group. The approach taken will also dictate the set of supporting documentation required as part of the registration process.

 

Practical considerations

Although registration deadlines have not yet been announced by the FTA, the availability of Pillar Two registration on the EmaraTax portal should prompt in-scope MNE groups to begin assessing their readiness for Pillar Two compliance in the UAE.

A key initial step is to confirm whether the group meets the applicability thresholds and to identify all UAE Constituent Entities, including any joint ventures or permanent establishments, that may fall within scope.

In addition, attention should be given to the availability and consistency of the data required for registration and future reporting, in particular financial information, to ensure alignment with group-level Pillar Two positions.

Lastly, while the registration process is now operational, further guidance from the FTA on timelines and other administrative aspects is expected, and should be monitored closely.

 

Key Takeaway

With Pillar Two registration now open on the EmaraTax portal, in-scope MNE groups should take this development to assess their Pillar Two readiness, determine the appropriate registration approach, and ensure that the necessary data are in place ahead of time.