UAE releases registration requirements for domestic minimum top-up tax

UAE entities within the scope of the UAE DMTT regime must submit a tax registration application to the FTA as follows:

Standard rule

• Within seven months from the end of the first fiscal year in which the entity is in scope of the DMTT rules.

Transitional rule

• For entities with a fiscal year ending before 30 April 2026, the tax registration application must be submitted no later than 30 November 2026, irrespective of the seven‑month rule.

KPMG observation
Registration will be via the FTA’s EmaraTax portal. For most in‑scope groups with a 31 December year‑end, the 30 November 2026 deadline will apply. For non‑calendar year ends, the same deadline applies if the fiscal year ends before 30 April 2026.

Entities that cease to be in scope of the UAE DMTT regime must submit a tax deregistration application as follows:

General rule

• Within six months from the earliest of:
  • the date the entity ceases to exist; or
  • the end of the fiscal year in which the entity leaves the MNE group and is no longer in scope of DMTT.

Transitional rule (early cessation)

• Where an entity ceases to exist before 30 June 2026, the deregistration application must be submitted no later than 31 December 2026.

Conditions for deregistration
Deregistration is only permitted after:

• all DMTT liabilities have been paid;
• all administrative penalties, if any, are settled; and
• all required DMTT returns and Pillar Two information returns have been submitted.

If a deregistration application is approved, tax registration remains valid until the earlier of:

• the date the entity ceases to exist;
• the end of the fiscal year in which the entity leaves the MNE group; or
• any other date determined by the FTA.

If an entity meets the conditions for deregistration but does not apply, the FTA may deregister the entity at its discretion.

KPMG observation
Deregistration is conditional on full compliance and not just an administrative formality. MNE groups undertaking restructurings, liquidations, disposals, mergers or redomiciliations should prepare for DMTT deregistration, build it into their transaction timeline and ensure all filings and payments are complete to avoid delays or FTA‑initiated actions.

The decision introduces a formal notification framework to manage cases where UAE entities move into and out of scope of DMTT over time.

When an entity falls out of scope – “Out-of-Scope Notification”

• If a UAE entity is part of an MNE group, and the MNE group no longer meets the criteria to be in scope of DMTT for a tested fiscal year, it must notify the FTA that it is out of scope.
• The out‑of‑scope notification must be submitted within six months from the end of the tested fiscal year in which the entity ceases to be in scope.
• Once submitted, the out‑of‑scope notification:
  • applies to that tested fiscal year; and
  • continues to apply for the next four consecutive fiscal years, unless the entity becomes in scope again and submits an in‑scope notification.

In practice, a single out‑of‑scope notification can cover up to five consecutive fiscal years (the tested fiscal year plus four subsequent years), provided the entity’s status does not change.

When an entity becomes in scope again – “In-Scope Notification”

• If, after submitting an out‑of‑scope notification, the entity again meets the DMTT in‑scope criteria in a subsequent fiscal year, it must submit an in‑scope notification to the FTA.
• This in‑scope notification must be submitted within seven months from the end of the tested fiscal year in which the entity becomes in scope again.

Mandatory deregistration after prolonged out‑of‑scope status

• If an entity remains out of scope of DMTT for five consecutive fiscal years (i.e., the tested fiscal year plus four additional years):
  • it is required to submit a tax deregistration application to the FTA; and
  • the deregistration application must be submitted within six months from the end of the fifth consecutive out‑of‑scope fiscal year.

KPMG observation
The notification framework acknowledges that DMTT in‑scope status can change over time. The five‑year limit before mandatory deregistration means groups need robust annual monitoring of DMTT status, with clear documentation and calendared notification and deregistration deadlines.

Where a domestic designated filing entity is appointed under the DMTT framework, that entity is responsible for:

• submitting tax registration applications;
• submitting tax deregistration applications; and
• filing in‑scope and out‑of‑scope notifications

on behalf of all relevant MNE group entities in the UAE.

KPMG observation
A DDFE can streamline DMTT compliance and concentrate responsibility in a single entity. Groups should ensure the DDFE has:

• appropriate access to EmaraTax;
• timely access to group data; and

clear governance and internal controls to manage all DMTT obligations (registrations, notifications, returns and deregistrations) within the prescribed timelines.