The FTA's top-up tax guide says who registers: groups over EUR 750 million, and nobody else

The Domestic Minimum Top-up Tax is the UAE's version of the OECD's 15 per cent floor, and the question every group finance team asks first is whether it applies to them. On 7 October the Federal Tax Authority published a guide that answers it: the Top-up Tax Guide on Scope and Registration.

The threshold

The tax applies to a multinational enterprise group with consolidated revenue of EUR 750 million or more in at least two of the four financial years before the one being tested. A group whose entities are all in the UAE is out of scope, whatever its size. The test is the group's, not the UAE entity's: a Dubai subsidiary of a group that passes it is in, however small the subsidiary.

When it started

Financial years beginning on or after 1 January 2025. The OECD granted the UAE's tax transitional qualified status on 18 August 2025, which is what lets a UAE top-up tax count towards a group's minimum rather than being paid twice.

What the guide covers

The guide walks through how the threshold is tested, how a group is defined, which entities are constituent entities, and the treatment of permanent establishments, joint ventures, and flow-through and hybrid entities. It covers the registration obligation and the Pillar Two Information Return, the filing a group makes to show how the minimum was computed.

The companion

The guide sits next to the authority's corporate tax guides and uses the same vocabulary; a group that has already mapped its UAE entities for the 9 per cent tax has done most of the scoping work for the 15 per cent floor.