UAE Pillar Two - Registration and deregistration timelines

The Federal Tax Authority (FTA) issued the Decision No. 12 of 2026 on 16 July 2026, effective for fiscal years starting on or after 1 January 2025.  The Decision sets out clear deadlines for Multinational Enterprise (MNE) group members to register and deregister for UAE Pillar Two (Top-Up Tax) purposes, and to notify the FTA when their in-scope status changes.

Registration 

Entities subject to Top-Up Tax must register with the FTA within 7 months from the end of their first in-scope fiscal year.  

Transitional deadline: If the entity's fiscal year ended before 30 April 2026, it must register on or before 30 November 2026.

Deregistration  

Entities must apply to deregister within 6 months from the earlier of: 

(a) the date the entity ceases to exist; or (b) the end of the fiscal year in which it leaves the MNE Group and is no longer in scope. 

Transitional deadline: If the entity ceased to exist before 30 June 2026, it must deregister on or before 31 December 2026. 

Important condition: An entity cannot be deregistered until all outstanding Top-Up Tax, penalties, and tax returns have been fully settled and filed. If an entity meets the deregistration requirements but has not applied, the FTA may deregister it at its own discretion.

In-scope and out-of-scope notifications

This Article applies to registered entities whose MNE group moves in or out of scope from year to year, without fully deregistering. 

• Out-of-scope notification: If the MNE Group falls out of scope for a fiscal year, the entity must notify the FTA within 6 months from the end of that fiscal year. 
• Validity: The notification covers the tested fiscal year and the next 4 consecutive fiscal years unless the entity re-enters scope. 
• In-scope notification: If the entity re-enters scope while an out-of-scope notification is still valid, it must submit an in-scope notification within 7 months from the end of that fiscal year. 
• Deregistration trigger: If the entity remains out of scope for 5 consecutive fiscal years, it must apply for deregistration within 6 months from the end of the fifth year, unless it re-enters scope. 

Groups should act now to assess their fiscal year 2025 in-scope status and confirm whether the transitional registration deadline of 30 November 2026 applies to them. They should also identify any deregistration deadline of 31 December 2026 that may apply. Processes should also be put in place to track in-scope/out-of-scope status annually and file the appropriate notifications on time.