23 August 2026 · Compliance
DMTT Registration & Filing
In-scope groups run a separate DMTT compliance track alongside their ordinary UAE corporate tax return, not instead of it. Each UAE constituent entity must register for the top-up tax, and the group must prepare a GloBE information return containing the data needed to compute the UAE effective tax rate and any resulting top-up. Filing and payment follow the deadlines set under the DMTT rules, and for the first years many groups can rely on the transitional CbCR safe harbour to avoid a full GloBE computation for the UAE if their country-by-country report passes a qualifying test. Either way, the real burden is not the arithmetic; it is assembling GloBE-standard financial data from every constituent entity across the group in time to file.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
What in-scope groups must do
DMTT compliance sits on top of, not instead of, the normal corporate tax return, and it carries its own registration, data and filing requirements. Every UAE constituent entity of an in-scope group needs to be identified and registered, even if only one entity in the UAE actually ends up owing a top-up payment. The group then prepares the GloBE information return, computes the UAE effective tax rate using the mechanics described elsewhere in this guide, and pays any shortfall by the applicable deadline.
- Register the UAE constituent entities for the top-up tax.
- Prepare the GloBE information return.
- Compute the UAE ETR and any top-up owed.
- File and pay by the DMTT deadlines.
- Identify every UAE constituent entity of the group, not just the obvious ones.
- Keep the DMTT filing separate from, but consistent with, the corporate tax return.
- Retain the underlying GloBE data in case of an FTA review.
It is a data project
The DMTT calculation itself is well defined; the practical difficulty is collecting GloBE-standard data from every constituent entity, in every jurisdiction the group operates in, on a consistent basis and in time to meet the filing deadline. Many finance teams find their existing systems were never built to produce GloBE income and covered tax figures directly, so a manual reconciliation process is needed in the early years. Groups that start this data project early (well before the deadline) avoid the scramble that catches those who treat DMTT as a return-day exercise.
- Collect GloBE-standard data from every constituent entity.
- Reconcile group accounting to GloBE adjustments.
- Coordinate across jurisdictions and finance teams.
- Build the process now, deadlines do not move.
- Existing ERP and accounting systems rarely output GloBE figures directly.
- A manual reconciliation is common in the first compliance cycles.
- Documentation should be retained to support the figures under review.
The transitional CbCR safe harbour
For the first years of the regime, a group can generally skip the full GloBE computation for the UAE if its qualified country-by-country report passes one of three tests: the de minimis test (UAE revenue below EUR 10 million and profit below EUR 1 million), the simplified ETR test, or the routine-profits test. Passing any one of the three means the UAE top-up is treated as zero for that period, a materially lighter compliance load than the full calculation. The safe harbour is assessed jurisdiction by jurisdiction and follows a strict 'once out, always out' principle: fail or skip it for the UAE in one year, and it is generally unavailable there in every later year, so the underlying CbCR data quality needs to be right from the very first filing.
- De minimis test: UAE revenue under EUR 10 million and profit under EUR 1 million.
- Simplified ETR test and routine-profits test are the other two available tests.
- Passing any one test treats the UAE top-up as zero for that period.
- Once the safe harbour is lost for the UAE, it cannot be reclaimed in later years.
Related guides
Frequently Asked Questions
For in-scope MNE groups planning their compliance and data-gathering timeline.
Do in-scope entities need to register separately?
Yes. UAE constituent entities register for the top-up tax in addition to their normal corporate tax registration and obligations. Every UAE entity belonging to an in-scope group needs to be identified for this purpose, not only the entity that ultimately owes a top-up payment.
What is the GloBE information return?
The return that reports the data used to compute the jurisdictional effective tax rate and any top-up under the Pillar Two rules: GloBE income, covered taxes, the substance-based exclusion and the resulting calculation for the UAE. It is prepared alongside, and must be consistent with, the group's ordinary corporate tax filings.
What makes DMTT compliance hard?
The volume and standardisation of data required across the group, not the calculation itself. Most finance systems were not built to output GloBE-defined figures directly, so early compliance cycles usually involve a manual data-gathering and reconciliation exercise across every jurisdiction the group operates in.
Can we avoid the full GloBE calculation?
Possibly, in the early years. If your UAE operations pass the transitional CbCR safe harbour's de minimis test, simplified ETR test, or routine-profits test, the UAE top-up can be treated as zero without running the full GloBE computation. This only applies for a transitional period and follows a once-out-always-out rule, so it is worth checking the safe harbour position before assuming it will always be available.
What happens if we miss the deadline?
As with other UAE tax obligations, late registration or late filing under the DMTT rules is expected to carry its own penalty exposure, on top of any top-up tax actually owed. Given how data-intensive the GloBE information return is, the practical risk is usually running out of time to gather accurate figures, which is why groups are advised to start the data process well ahead of the filing date rather than at the deadline.
Does DMTT filing replace our normal corporate tax return?
No. The DMTT filing and payment obligation runs alongside the standard UAE corporate tax return, not instead of it. In-scope groups continue to file corporate tax as normal and separately register, compute and, where a top-up arises, file and pay under the DMTT rules.
Can Exiloz manage our DMTT filing?
Yes. We register your UAE constituent entities, build the GloBE data collection process across the group, check your position against the transitional CbCR safe harbour, and prepare the GloBE information return with our specialist network, so the deadline is met with figures you can stand behind.
Get DMTT compliance under control
Exiloz registers your UAE entities, builds the GloBE data process, checks your safe harbour position and files your return so the deadline is never a crisis.