UAE Pillar Two – Registration Now Open

Recently, the UAE Federal Tax Authority has activated the Pillar Two registration functionality on the Emara Tax portal.

Entities that are members of MNE groups meeting the Pillar Two revenue threshold (i.e., consolidated group revenue exceeding EUR 750 million in at least two of the four preceding fiscal years) are required to register and obtain a Pillar Two Top-up Tax Registration Number. Separate registration is required for Joint Ventures, Joint Venture groups and for reverse hybrid entities.

Earlier, UAE had passed Cabinet Decision No (142) of 2024 implementing minimum tax of 15% for large multinational enterprise (MNE) groups as per the Pillar Two Rules published by OECD. Pillar Two obligations are applicable for all large MNE groups from the financial year starting on or after 1st January 2025.

REGISTRATION REQUIREMENTS

Based on the registration framework currently released, Taxpayers may either:

• Register individually; or
• Designate a UAE constituent entity as the Domestic Designated Filing Entity (DDFE) to undertake Pillar Two compliance obligations on behalf of all UAE constituent entities within the group. All such CEs who have nominated DDFE in their registration application shall provide authorisation for appointment of DDFE. The designated DDFE must submit an authorization letter confirming its appointment, which must be acknowledged by the relevant UAE constituent entities covered under the arrangement.

The registration process requires submission of various details and supporting documents, including information relating to the MNE Group, Ultimate Parent Entity (UPE), Group structure, DDFE (where applicable) from relevant UAE group entities.

• While the UAE tax authorities have not yet announced a specific deadline for registration, MNE groups with operations in the UAE should begin assessing their Pillar Two obligations and prepare for compliance requirements.
• Groups with multiple Joint Ventures (JVs) may face increased compliance obligations, as each JV and JV Group may be required to undertake a separate registration process.
• The registration process requires the collection and submission of various supporting documents. To facilitate timely registration, MNE groups should start coordinating with relevant UAE constituent entities to obtain the necessary Letters of Authorization and other required documentation.