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Domestic Minimum Top-up Tax: scope and threshold

Applies
FY2025 onwards
Reviewed
Rule
UAE-CT-DMTT-SCOPE-2025.1
By

Which groups are in scope of the UAE DMTT?

UAE entities of a multinational group with revenue of EUR 750 million or more in at least 2 of the four preceding years. Investment Entities are not.

Per Cabinet Decision No. 142 of 2024, The Imposition of Top-up Tax on Multinational Enterprises, Articles 1 and 2 of the attached Legislation

The Decision applies to Constituent Entities that are members of an MNE Group with annual revenue at or above the published threshold in the Consolidated Financial Statements of the Ultimate Parent Entity in at least the published number of the four Fiscal Years immediately preceding the tested Fiscal Year, with a Fiscal Year shorter than twelve months measured against a proportionally adjusted threshold. The Top-up Tax is paid by Constituent Entities located in the UAE, Joint Ventures and JV Subsidiaries located in the UAE, and Stateless Constituent Entities created under UAE law that are Reverse Hybrid Entities. A Constituent Entity does not include an Excluded Entity, and an Investment Entity located in the UAE is not subject to the Top-up Tax.

The gate to the top-up tax stage. Being within the group threshold is not the same as being liable: the charging provision names specific Entities, and two categories are outside it altogether.

The group test, and who actually pays

1.1.1 — the threshold test, which looks backwards

Annual revenue at or above the published threshold in the Ultimate Parent Entity's Consolidated Financial Statements, in at least the published number of the four Fiscal Years IMMEDIATELY PRECEDING the tested year. Not the tested year itself — a group below the threshold this year can be in scope, and a group above it for the first time this year is not.

1.1.2 — a short Fiscal Year is adjusted proportionally

Where one of the four years is not twelve months, the threshold for that year is adjusted proportionally to its length. Comparing a nine-month year against the full threshold understates the count of qualifying years, and can put a group out of scope that is in it.

1.2 — MNE Group and Group

  • 1.2.1 — an MNE Group is a Group that includes at least one Entity or Permanent Establishment not located in the Ultimate Parent Entity's Jurisdiction
  • 1.2.2 — a Group is a collection of Entities related through ownership or control whose accounts are consolidated in the UPE's Consolidated Financial Statements, or excluded from them only on size, materiality or held-for-sale grounds
  • 1.2.3 — a Group also means a single Entity in one Jurisdiction with one or more Permanent Establishments in others, provided it is not part of another Group

2.1 — the Entities that pay

  • (a) Constituent Entities located in the UAE during the Fiscal Year, including members of a Minority-owned Subgroup
  • (b) Joint Ventures and JV Subsidiaries located in the UAE during the Fiscal Year
  • (c) Stateless Constituent Entities created under the laws of the UAE that are Reverse Hybrid Entities, as to their allocated Pillar Two Income or Loss

Two categories are outside the charge

  • 1.3.3 — a Constituent Entity does not include an Entity that is an Excluded Entity
  • 2.3 — an Investment Entity located in the UAE is not subject to the Top-up Tax

2.2 — and who may pay on whose behalf

The Constituent Entities of a Domestic Main Group or Domestic Minority-owned Subgroup, the members of a Domestic JV Group, and the Reverse Hybrid Entities in 2.1(c), may each appoint a Domestic Designated Filing Entity to pay the Top-up Tax on their behalf.

Excluded Entities — Article 1.5 of the Decision

  • 1.5.1: a Governmental Entity, an International Organisation, a Non-profit Organisation, a Pension Fund, and an Investment Fund or Real Estate Investment Vehicle that is an Ultimate Parent Entity
  • 1.5.2: an Entity at least 95% owned by such Entities that exists to hold assets or invest funds for them or carries out only ancillary activities; or at least 85% owned where substantially all its income is excluded dividends or equity gains
  • A Filing Constituent Entity may elect, for five years, not to treat a 1.5.2 Entity as excluded (1.5.3). The FTA's guide TTGEIE1 sets out each category in detail; the category is the reader's determination

Registration — FTA Decision No. 12 of 2026

  • Register for Top-up Tax within seven months of the end of the first Fiscal Year in which the Entity is in scope; for a Fiscal Year ending before 30 April 2026, by 30 November 2026
  • A group that falls out of scope files an out-of-scope notification within six months of the tested year's end, valid for that year and the next four
  • Where a Domestic Designated Filing Entity is appointed under Article 2.2, it registers and notifies for the members it represents

Mergers and demergers — Article 6.1

Article 1.1.1 is applied to the consolidated revenue as Article 6.1 modifies it where groups merge or a group demerges. The figures supplied for each year are to be the Article 6.1 figures where it applies.

Order of testing

  1. 1

    Inputs requiring your determination

    Any input a person must decide and has not decided stops the computation. An undecided input is never read as a no.

  2. 2

    An MNE Group

    Article 1.2.1. Without an Entity or Permanent Establishment outside the UPE's Jurisdiction there is no MNE Group — though Article 1.2.3 makes a single Entity with foreign Permanent Establishments a Group, which is a determination.

  3. 3

    Consolidated revenue in the preceding Fiscal Years

    Each of the four preceding years is compared against the published threshold, adjusted proportionally where the year was shorter than twelve months, and the qualifying years are counted against the published minimum.

  4. 4

    The Entities that pay the Top-up Tax

    Article 2.1, read with Articles 1.3.3 and 2.3. A group can be in scope while a particular Entity is outside the charge, and the result says which provision decided it.

Examples

Illustrative scenarios — ours, not the authority’s — each computed live by this rule. Change any fact and the outcome is the rule’s, not a hand-written answer.

A large group, two qualifying years, a UAE subsidiary

An MNE Group whose consolidated revenue met the threshold in two of the four preceding years and fell below it in the other two, with a UAE Constituent Entity.

Computed

The Entity is within the scope of the Decision and within its charge as computed: the annual revenue in the Ultimate Parent Entity's Consolidated Financial Statements met the published threshold of EUR 750,000,000 in 2 of the four Fiscal Years immediately preceding this one, which satisfies the 2 that Article 1.1.1 requires, and Article 2.1(a) — a Constituent Entity located in the UAE during the Fiscal Year, including one that is a member of a Minority-owned Subgroup. Whether any Top-up Tax arises is a separate computation under Article 5, and a safe harbour may deem it to be zero — but registration does not wait for that: FTA Decision No. 12 of 2026 requires a Top-up Tax registration application within seven months of the end of the first Fiscal Year in scope (by 30 November 2026 for a Fiscal Year ending before 30 April 2026), made by the Domestic Designated Filing Entity where one is appointed. Based on the figures you supplied.

Workings

FY2025 consolidated revenueagainst the published threshold of EUR 750,000,000 — meets it
EUR 820,000,000
FY2024 consolidated revenueagainst the published threshold of EUR 750,000,000 — meets it
EUR 760,000,000
FY2023 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 640,000,000
FY2022 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 590,000,000
Preceding Fiscal Years meeting the thresholdArticle 1.1.1 requires at least 2 of the four immediately preceding Fiscal Years
2

Decided by the entities that pay the top-up tax

One qualifying year only

The same group with only one of the four preceding years at or above the threshold — not in scope, however large the tested year turns out to be.

Computed

The Decision does not apply as computed: Article 1.1.1 requires annual revenue of at least EUR 750,000,000 in the Ultimate Parent Entity's Consolidated Financial Statements in at least 2 of the four Fiscal Years immediately preceding the tested year, and 1 of the 4 years you supplied meets it. The test looks at those years and not at the tested year, so revenue in this year does not change the answer. Based on the figures you supplied.

Workings

FY2025 consolidated revenueagainst the published threshold of EUR 750,000,000 — meets it
EUR 820,000,000
FY2024 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 700,000,000
FY2023 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 640,000,000
FY2022 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 590,000,000
Preceding Fiscal Years meeting the thresholdArticle 1.1.1 requires at least 2 of the four immediately preceding Fiscal Years
1

Decided by the consolidated revenue in the preceding fiscal years

A short Fiscal Year, measured proportionally

A group with a nine-month transitional year of EUR 600,000,000 — below the full threshold but above nine twelfths of it, which Article 1.1.2 makes the comparison.

Computed

The Entity is within the scope of the Decision and within its charge as computed: the annual revenue in the Ultimate Parent Entity's Consolidated Financial Statements met the published threshold of EUR 750,000,000 in 2 of the four Fiscal Years immediately preceding this one, which satisfies the 2 that Article 1.1.1 requires, and Article 2.1(a) — a Constituent Entity located in the UAE during the Fiscal Year, including one that is a member of a Minority-owned Subgroup. Whether any Top-up Tax arises is a separate computation under Article 5, and a safe harbour may deem it to be zero — but registration does not wait for that: FTA Decision No. 12 of 2026 requires a Top-up Tax registration application within seven months of the end of the first Fiscal Year in scope (by 30 November 2026 for a Fiscal Year ending before 30 April 2026), made by the Domestic Designated Filing Entity where one is appointed. Based on the figures you supplied.

Workings

FY2025 consolidated revenuea 9-month Fiscal Year, so Article 1.1.2 adjusts the threshold proportionally to EUR 562,500,000 — meets it
EUR 600,000,000
FY2024 consolidated revenueagainst the published threshold of EUR 750,000,000 — meets it
EUR 780,000,000
FY2023 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 500,000,000
FY2022 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 480,000,000
Preceding Fiscal Years meeting the thresholdArticle 1.1.1 requires at least 2 of the four immediately preceding Fiscal Years
2

Decided by the entities that pay the top-up tax

An Investment Entity in the UAE

The same in-scope group, where the Entity in question is an Investment Entity located in the UAE — which Article 2.3 puts outside the Top-up Tax.

Computed

The MNE Group is within the scope of the Decision as computed — the threshold is met in 2 of the four preceding Fiscal Years — but this Entity is not one that pays the Top-up Tax: Article 2.3 — an Investment Entity located in the UAE is not subject to the Top-up Tax. That the Group is in scope still matters for the other Entities in it, and for the filing obligations the Decision imposes. Based on the figures you supplied.

Workings

FY2025 consolidated revenueagainst the published threshold of EUR 750,000,000 — meets it
EUR 820,000,000
FY2024 consolidated revenueagainst the published threshold of EUR 750,000,000 — meets it
EUR 760,000,000
FY2023 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 640,000,000
FY2022 consolidated revenueagainst the published threshold of EUR 750,000,000 — below it
EUR 590,000,000
Preceding Fiscal Years meeting the thresholdArticle 1.1.1 requires at least 2 of the four immediately preceding Fiscal Years
2

Decided by the entities that pay the top-up tax

A purely domestic group

A large UAE group with no Entity or Permanent Establishment outside the UAE, so there is no MNE Group.

Computed

The Decision does not apply as computed: Article 1.1.1 applies to Constituent Entities that are members of an MNE Group, and Article 1.2.1 makes a Group an MNE Group only where it includes at least one Entity or Permanent Establishment that is not located in the Ultimate Parent Entity's Jurisdiction — which you have indicated it does not. Note that Article 1.2.3 also makes a single Entity with Permanent Establishments in other Jurisdictions a Group, which requires your determination.

Decided by the an mne group

Try it

Supply the facts and this rule computes the outcome in your browser, live. Leave a determination undecided and it blocks the result — it is never read as a no.

Consolidated revenue, preceding Fiscal Years

One row for each of the four Fiscal Years immediately preceding the tested year, in euro, from the Ultimate Parent Entity's Consolidated Financial Statements. A row with no revenue is ignored. Enter the months only for a Fiscal Year that was not twelve months long.

Not computed yet

3 inputs still need your determination:

  • Is the Group an MNE Group — does it include at least one Entity or Permanent Establishment that is not located in the Jurisdiction of the Ultimate Parent Entity?
  • What is the Entity's position — a Constituent Entity in the UAE, a Joint Venture or JV Subsidiary in the UAE, a Stateless Reverse Hybrid created under UAE law, an Excluded Entity, an Investment Entity in the UAE, or not located in the UAE?
  • What was the annual revenue in the Ultimate Parent Entity's Consolidated Financial Statements in each of the four Fiscal Years immediately preceding this one? The test looks at those years, not at the tested year.

Computed in your browser from the figures you supply. Nothing is sent anywhere, and the result is a computation against a rule — reference, not tax advice.

Thresholds

uae.dmtt_consolidated_revenue_threshold
EUR 750,000,000 · reviewed 2026-09-28 · source
uae.dmtt_qualifying_preceding_years
count 2 · reviewed 2026-09-28 · source

Threshold values are published separately from the rule and carried with a citation. Where none has been published for the period being computed, the rule reports that rather than applying a default.

Sources

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Reference, not tax advice.

Pankaj Agarwal — Tax Technology Leader