UAE Pillar Two Top-up Tax Registration Now Live on EmaraTax

Created By : Yeeshu Sehgal | UAE Tax Lead

If your business hits the EUR 750 million mark, your tax calendar just got a lot busier. Are you ready to register?

For months, multinational groups have been keeping a close eye on the UAE's stance on the OECD's Pillar Two Global Minimum Tax framework. Finally, the transition from policy to practice is complete. The Federal Tax Authority (FTA) has officially launched the Pillar Two Top-up Tax registration module on EmaraTax. If your group hits that €750 million global revenue mark (is a multinational enterprise (MNE) group), the clock is officially ticking.

This registration is far more than an administrative formality. It acts as the DNA for your filing responsibilities and reporting authority moving forward. Let’s break down what this milestone means for your business - and why waiting until the deadline is a compliance risk you simply don't want to take.

What Has Happened

The FTA has activated the Pillar Two Top-up Tax registration module on EmaraTax. This covers the UAE's implementation of the OECD's global minimum tax rules - specifically the Domestic Minimum Top-up Tax (DMTT), which applies to large multinational groups operating in the UAE.

Registration is not a formality. It determines which entity within your group is responsible for filing, who has authority to act on behalf of other group members, and how the FTA interacts with your group going forward. Getting it set up correctly from the start matters.

Two Ways to Register - Which One Applies to You?

The questionnaire on EmaraTax routes you into one of two registration paths depending on your group's structure:

1. Domestic Designated Filing Entity (DDFE)

This route applies where your group has multiple UAE entities and one of them will file and pay on behalf of the whole domestic group. This is the more common path for groups with a meaningful UAE presence.

2. Individual Entity Registration

This route applies where your group does not have a DDFE – typically because there is only one UAE entity, or the group has not appointed one. Each entity registers separately.

One important point from the questionnaire: if your group has consolidated revenue below EUR 750 million and the scope is not triggered by a merger, acquisition, or demerger, EmaraTax will block submission and return you to the dashboard. The system screens for eligibility upfront.

Registering as a Domestic Designated Filing Entity - Step by Step

The DDFE path has seven stages on EmaraTax. Here is what each one involves:

Registering as an Individual Entity - Step by Step

For entities registering individually, the process is shorter and consists of five stages:

Step 1 – Questionnaire

Select individual registration, confirm the EUR 750 million threshold, confirm whether the scope is triggered by a merger, acquisition, or demerger, and select the type of group – Domestic Main Group, Domestic Minority-Owned Subgroup, Reverse Hybrid Entity, or Domestic JV Group.

Step 2 – MNE Group Information

As with the DDFE path, provide the group name, reporting fiscal year dates, multi-parented MNE confirmation, Ultimate Parent Entity details, and corporate structure documents.

Step 3 – Constituent Entity / JV Details

TIN and entity name will auto-populate. Confirm PE status, excluded entity status, investment entity status, and whether you wish to appoint a Designated Local Entity.

Step 4 – Authorised Signatory

Add signatory details, including the name in English and Arabic, ID number, and email address.

Step 5 – Review and Declaration

Conduct a final review and submit the registration.

What You Need to Have Ready Before You Start

A few things will slow the registration down if they are not prepared in advance:

1. Corporate structure chart covering the entire MNE group, including entities inside and outside the UAE and the controlling interests each group entity holds in others. This is mandatory for both registration paths.
2. TIN and jurisdiction details for the Ultimate Parent Entity. If the UPE is in a jurisdiction that does not issue a TIN, you will need to understand how EmaraTax handles this before reaching Step 2.
3. Letters of authorization from all UAE group entities if registering as a DDFE, or be prepared to initiate the EmaraTax acknowledgement process and obtain responses within the 14-business-day window.
4. Authorised signatory details, including Emirates ID or passport number and the email address registered with the FTA.

A Few Things Worth Watching

The acknowledgement step for DDFE registrations is the one most likely to cause delays. If any entity in the group does not respond within 14 days, the request gets cancelled and the process has to restart. If your group has several UAE entities, it is advisable to obtain the authorization letters upfront rather than relying on the EmaraTax request flow.

The Excel template for Domestic Group Entity Details was last updated 30 May 2025. If you have used an older version of the template in a draft application, download the current one before uploading.

The system does not allow submission until every stage is marked complete. The “Save as Draft” functionality is available throughout the process and should be used where required. The registration can be completed in stages, but all information must remain consistent across sections before the FTA will accept the submission.

How AKM Global Can Help

If you require assistance in assessing applicability, determining the appropriate registration route, preparing the required documentation, or completing the registration process, please feel free to reach out to our Dubai office at info@akmglobal.in.

We have already worked through the EmaraTax registration process and can help your group complete the registration efficiently and accurately.