The UAE’s Pillar Two framework continues to take shape.
FTA Decision No. 12 of 2026 sets out the registration, deregistration and notification requirements for entities subject to the UAE Top up Tax regime under Cabinet Decision No. 142 of 2024.
For affected multinational groups, the Decision provides greater clarity around an important practical question: what needs to be filed with the FTA, and when?
Seven Months to Register
An entity subject to Top up Tax must submit its Tax Registration application within seven months from the end of the first Fiscal Year in which it falls within scope.
The Decision also provides transitional relief for earlier Fiscal Year ends.
Where an entity’s Fiscal Year ends before 30 April 2026, the registration application must instead be submitted on or before 30 November 2026.
This fixed deadline is particularly relevant for groups with December 2025 and March 2026 year ends.
What Happens When an Entity Leaves the Regime?
The Decision also establishes a clear process for deregistration.
Generally, an entity must apply within six months from the relevant trigger, which may arise when the entity ceases to exist or when it leaves an MNE Group and is no longer within scope.
Deregistration also requires outstanding Top up Tax and penalties to be settled and the relevant Top up Tax Returns and Pillar Two Information Returns to be filed.
Scope Needs to Be Monitored Each Year
Pillar Two compliance is not limited to initial registration.
Where an MNE Group falls out of scope, an out of scope notification is generally required within six months from the end of the relevant Fiscal Year. That notification can remain valid for the tested Fiscal Year and the following four consecutive Fiscal Years.
If the group comes back into scope during that period, an in scope notification is required within seven months from the end of the relevant Fiscal Year.
This makes annual monitoring of the group’s Pillar Two status an important part of the compliance process.
One Filing Entity Can Represent the Group
Where a Domestic Designated Filing Entity has been appointed, it can submit registration and deregistration applications as well as scope notifications on behalf of the relevant group members.
This creates a single filing point for the group’s UAE Pillar Two compliance obligations rather than requiring separate filings from each member.
Building a Pillar Two Compliance Calendar
The practical takeaway from Decision No. 12 is that Pillar Two compliance now involves several different timelines.
Businesses should understand when their first Fiscal Year falls within scope, identify the relevant registration deadline and continue monitoring changes in group status from year to year.
For affected groups, building these requirements into the broader Pillar Two compliance calendar can help create a more structured approach to registration, notifications, returns and ongoing compliance.
How MCA Gulf Can Help
MCA Gulf can support businesses in assessing the applicability of the UAE Top up Tax rules, identifying registration and notification obligations, mapping the relevant deadlines and supporting submissions to the FTA.
For a working session, contact us.
Download the Guide
Download our guide for a practical overview of FTA Decision No. 12 of 2026 and the registration, deregistration and notification requirements under the UAE Pillar Two regime.
