UAE Federal Tax Authority issues QDMTT guidance for multinationals

The Federal Tax Authority issued guidance on the qualified domestic minimum top-up tax for multinational enterprises operating in the United Arab Emirates. The guide addresses scope determination, registration procedures and filing timelines for corporations subject to the QDMTT legislation, published on 7 October 2026.

QDMTT scope and registration requirements#

The guidance details conditions for multinational enterprise groups to fall within scope of the top-up tax, types of entities subject to the levy and those excluded, and the registration process with applicable deadlines. It provides explanations and examples covering treatment of permanent establishments, joint ventures, flow-through entities and hybrid entities. The document addresses entity location determination, registration procedures and filing requirements for the Pillar Two Information Return, a standardised annual template required under the Organisation for Economic Co-operation and Development framework.

15 percent rate applies above €750 million threshold#

The UAE imposes a 15 percent top-up tax on large multinational corporations with annual revenue of €750 million or above. The measure forms part of the OECD and G20 Two-Pillar Solution addressing tax challenges from digitalisation of the economy, including the Global Anti-Base Erosion Model Rules. The UAE received transitional qualified status in the OECD central record in August 2025, according to the authority.

Authority commits to taxpayer support#

The Federal Tax Authority stated the guide supports multinational businesses in understanding the country's tax framework and meeting registration obligations. The authority said it remains committed to supporting taxpayers and facilitating voluntary compliance through comprehensive guidance and continued engagement with the business community. It advised the guide should be read in its entirety to gain a comprehensive understanding of definitions, requirements and interaction between different rules.

Filing and compliance obligations detailed#

The guidance outlines the filing process for the Pillar Two Information Return, registration timelines and procedures multinational enterprises must follow to comply with the QDMTT legislation. It clarifies which entities within a multinational group structure are subject to the top-up tax and which fall outside its scope, with practical examples provided for different entity types and structures operating in the UAE.