Key facts
- The Federal Tax Authority issued a Top-up Tax guide on scope and registration for multinational enterprise groups on 7 October 2026.
- The UAE Domestic Minimum Top-up Tax applies for financial years starting on or after 1 January 2025 and aims for an effective tax rate of at least 15%.
- It covers UAE entities of groups with consolidated revenue of EUR 750 million or more in at least two of the four previous financial years.
- Groups that operate only in the UAE are out of scope, whatever their revenue.
What happened
On 7 October 2026 the Federal Tax Authority published a new guide explaining the scope of the Domestic Minimum Top-up Tax for multinational enterprise groups and how in-scope groups register. The tax is the UAE’s version of the global minimum tax rules. It applies for financial years beginning on or after 1 January 2025 and is designed to bring the effective tax rate of large groups to at least 15% in the UAE.
The guide explains which entities count, including permanent establishments, joint ventures, flow-through entities and hybrid entities, how registration works, and how the Pillar Two information return fits in. The FTA notes that the UAE was listed in the OECD central record on 18 August 2025 with transitional qualified status.
Source: Federal Tax Authority, FTA issues new guide on scope and registration for Top-up Tax on multinational enterprises, Abu Dhabi, 7 October 2026. The guide itself is published under Corporate Tax guides on tax.gov.ae. Checked by Noble Core on 12 October 2026.
What it means for founders
For most founders this guide changes nothing. A startup or SME in a free zone or on the mainland is far below the EUR 750 million group revenue line, and a business that operates only in the UAE is out of scope at any size. Your Corporate Tax position stays as it is.
The people who should read it are finance teams of large foreign groups that have, or plan, a UAE subsidiary, branch or joint venture. That includes many UK, US and European groups that use a UAE entity as a regional hub. For them, the practical point is that every UAE entity and permanent establishment of the group needs to be mapped before a new structure is chosen, because each one can be a constituent entity for this tax. Our advice is simple: decide the UAE structure after the group tax team has done that mapping, not before.
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Who is affected and who is not
- Foreign groups with EUR 750 million or more in consolidated revenue in two of the last four years, with UAE entities or a UAE permanent establishment: in scope. Read the registration section of the guide now.
- UAE-only groups: out of scope, whatever the revenue.
- SMEs, startups and free zone companies below the revenue line: not affected. Normal Corporate Tax rules continue to apply.
- Groups near the threshold: watch the two-of-four-years test, because crossing it changes your position.
What to do now
- Check group consolidated revenue against EUR 750 million for each of the last four financial years.
- List every UAE entity, branch and permanent establishment in the group.
- Read the registration section of the FTA guide and note the steps that apply to you.
- Brief your registered tax agent before any new UAE entity is set up.
- Confirm the requirements and dates on tax.gov.ae before you act.
How Noble Core helps
We set up and restructure UAE entities for foreign groups and handle Corporate Tax registration through official channels. Top-up Tax analysis is work for a registered tax agent, and we will say so plainly if your group needs one. Message us on WhatsApp or call +971 52 253 5694.
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Noble Core uses AI tools to help research and draft these updates. Every fact is checked against the official source linked above. Read our editorial policy. Noble Core Ventures is an independent business setup consultancy, not a government body.
