The UAE Federal Tax Authority (FTA) has issued a Top-up Tax Guide on Scope and Registration for multinational enterprise (MNE) groups. It covers how to determine whether a group is within the scope of the Qualified Domestic Minimum Top-up Tax (QDMTT) legislation, which entities are and are not subject to the tax, and the registration process and timelines.
The guide includes worked examples on permanent establishments, joint ventures, flow-through and hybrid entities, the location of entities, and the filing of the Pillar Two Information Return. It is aimed at those responsible for the tax affairs of group entities and at tax agents.
According to the FTA, the QDMTT applies for fiscal years beginning on or after 1 January 2025 to UAE constituent entities of MNE groups with annual revenue of EUR 750 million or more in the ultimate parent's consolidated financial statements in at least two of the four preceding fiscal years. Groups operating only within the UAE are outside its scope, whatever their revenue.
Source: UAE Federal Tax Authority