UAE Pillar Two Top-up Tax Registration Now Available Through the EmaraTax Portal

The UAE Federal Tax Authority (FTA) has activated the registration process for entities within the scope of the OECD’s Pillar Two Global Minimum Tax rules through the EmaraTax portal.

This marks another significant step in the UAE’s implementation of the Pillar Two framework and highlights the importance of assessing compliance obligations well ahead of filing deadlines.

In-scope groups may initiate the registration process through one of two pathways:
Domestic Designated Filing Entity (DDFE) Registration – A designated constituent entity may register and act on behalf of the relevant domestic group.
Individual Entity Registration – Where no DDFE has been appointed, each constituent entity (or qualifying joint venture entity) must register separately.
It is important to note that where a DDFE is appointed, ALL entities within the domestic group must register through that DDFE. Conversely, where no DDFE is appointed, ALL entities are required to register individually. Taxpayers are required to submit an application through EmaraTax, which will be reviewed by the FTA before registration is approved.

As highlighted by the FTA, failure to register may expose entities to:

Administrative penalties under the UAE Tax Procedures Law
Increased compliance risk under FTA regulations
Potential complications in meeting group-level Pillar Two reporting obligations
While further guidance from the FTA is expected, we have prepared a practical walkthrough of both registration pathways and the key information and documentation required as part of the registration process.