For an in-scope calendar-year group whose first UAE DMTT fiscal year ended on 31 December 2025, the main UAE dates are not the same: Top-up Tax registration is due by 30 November 2026 under the transitional registration rule; the UAE Pillar Two Information Return, or the relevant foreign-filer notification, is generally due by 31 March 2027; and the first Top-up Tax Return and payment are generally due by 30 June 2027 because the 18-month transition-year filing period applies to the tax return.
A global Pillar Two calendar must also track each jurisdiction's IIR, UTPR and qualified domestic minimum top-up tax effective dates, registrations, local notifications, GIR filing or exchange arrangements, domestic returns, payments and amendment procedures. A central GIR filing does not automatically remove every local notification or QDMTT return.
The calendar should be maintained as a controlled statutory process. Every date needs a legal source, responsible entity, preparer, reviewer, data cut-off and evidence of submission. Because implementation and qualified status can change, the group should refresh the calendar at least quarterly and immediately after an acquisition, disposal, reorganisation or entry into a new jurisdiction.
What are the main UAE Pillar Two deadlines for a calendar-year group?
The UAE DMTT applies for fiscal years beginning on or after 1 January 2025 under Cabinet Decision No. 142 of 2024. For a group with a 31 December year-end and FY2025 as its first UAE in-scope year, the central timetable is:
| UAE obligation | General rule | FY2025 calendar-year illustration |
|---|---|---|
| Top-up Tax registration | Within seven months after the end of the first fiscal year in scope; transitional rule for early-ending periods | 30 November 2026 |
| Pillar Two Information Return or foreign-filer notification | No later than 15 months after the last day of the reporting fiscal year | 31 March 2027 |
| First Top-up Tax Return | Normally 15 months after year-end, extended to 18 months for the transition year | 30 June 2027 |
| UAE top-up tax payment | By the Top-up Tax Return filing deadline | 30 June 2027 |
These dates assume the group remained in scope, FY2025 is the relevant transition year and no fact-specific rule changes the outcome. Groups with non-calendar year-ends must calculate their own dates from the statutory rules. A June, September or March year-end should not copy the calendar-year dates.
The Ministry of Finance Top-up Tax page confirms the general scope and effective date. SBC's complete UAE Pillar Two DMTT guide provides the wider calculation and filing context.
When is UAE Top-up Tax registration due?
FTA Decision No. 12 of 2026 sets the registration and deregistration timelines. An entity subject to Top-up Tax must generally submit its registration application within seven months after the end of the first fiscal year in which it is in scope.
A transitional rule applies where that first in-scope fiscal year ended before 30 April 2026: registration is due by 30 November 2026. This captures the common case of a calendar-year group whose first UAE DMTT period ended on 31 December 2025.
The group should not assume that appointing one coordinating company automatically completes every entity's registration position. It must determine whether each UAE entity will register and act for itself or whether a properly appointed Domestic Designated Filing Entity, or DDFE, will represent members of the domestic group under the applicable rules.
The FTA's current Top-up Tax guides and references should be used for scope, registration, excluded-entity and operational guidance. The registration tracker should record the entity, tax registration number, role, application date, authorisation, confirmation and any represented entities.
When is the UAE Pillar Two Information Return due?
The UAE Pillar Two Information Return, or P2IR, is an information-reporting obligation distinct from the Top-up Tax Return. Article 15.4 of the UAE framework sets a deadline no later than 15 months after the last day of the reporting fiscal year for the P2IR and related notification.
For a reporting fiscal year ending on 31 December 2025, 15 months ends on 31 March 2027. The transition-year extension used for the first Top-up Tax Return should not automatically be applied to the P2IR.
Ministerial Decision No. 133 of 2026 identifies the UAE entities required to file and the conditions for filing through a Designated Local Entity. The same entity may potentially hold more than one role, but the legal appointments and responsibilities remain distinct.
SBC's guide to the UAE Pillar Two Information Return explains the filing population, DLE mechanism and information architecture.
When is the first UAE Top-up Tax Return and payment due?
The Top-up Tax Return is generally due within 15 months after the fiscal year-end, with an 18-month period for the transition year of any constituent entity in the MNE group under the applicable rule. Payment is due by the return deadline.
For a 31 December 2025 year-end that qualifies as the transition year, 18 months ends on 30 June 2027. This is three months after the 31 March 2027 P2IR deadline. Treating the two returns as one deliverable can therefore create a control failure: the information return may be due while the final tax-return review is still continuing.
The group should work back from both dates. The P2IR needs a sufficiently final entity map, elections, safe-harbour positions and jurisdictional information by March. The tax return then needs the final UAE computation, allocation, payment instruction and sign-off by June.
What is the difference between a DLE and a DDFE?
The Designated Local Entity and Domestic Designated Filing Entity perform different functions.
| Role | Primary responsibility | Calendar control |
|---|---|---|
| Designated Local Entity (DLE) | Files the P2IR, or relevant foreign-filer notification, for represented UAE entities | Track appointment, represented entities and P2IR/notification deadline |
| Domestic Designated Filing Entity (DDFE) | Handles specified UAE registration, Top-up Tax Return and payment responsibilities for represented domestic group members | Track registration, authorisation, return, payment and separate domestic-group populations |
The legal documents, EmaraTax access and internal responsibility matrix should use the correct role name. A group may decide to use the same UAE company operationally, but it should not merge the roles in its governance memo.
What is a complete global Pillar Two compliance calendar?
A complete calendar is more than a list of GIR due dates. It tracks every event that can create, change or discharge an obligation in each jurisdiction.
| Obligation category | What to record | Why it is missed |
|---|---|---|
| Scope and effective date | IIR, UTPR and QDMTT start year; revenue test; entity classification | Different rules started in different years |
| Registration | Entity, tax identifier, portal, deadline and representative | Often due before the first tax return |
| GIR/P2IR filing | Filer, exchange agreement, filing format and deadline | Central filing may be assumed without checking exchange conditions |
| Local notification | Local entities represented, designated filer and due date | Can remain due even when the GIR is filed abroad |
| QDMTT/DMTT return | Domestic computation, filer, currency, deadline and amendment process | Separate from the global information return |
| IIR/UTPR return | Parent or local allocation, domestic form and due date | Domestic compliance differs by jurisdiction |
| Payment | Currency, bank process, approval, instalments and final date | Treasury lead time is omitted from the tax calendar |
| Record retention | Calculation files, elections, source data and submission receipts | Evidence ownership is not assigned |
The calendar must be entity-aware. A country may have one filing entity for the GIR but multiple taxpayers or domestic minimum-tax returns. Joint ventures, minority-owned subgroups, permanent establishments and investment entities can create separate workstreams.
When did IIR, UTPR and domestic minimum taxes start globally?
Implementation occurred in waves. Many early-adopter jurisdictions applied the Income Inclusion Rule and a domestic minimum tax for fiscal years beginning in 2024, with the UTPR generally following from 2025. The EU Minimum Tax Directive established the framework for EU Member States, while other jurisdictions enacted their own domestic rules and dates.
The UAE began its DMTT for fiscal years starting on or after 1 January 2025 and does not currently apply an IIR. A UAE-headquartered group can nevertheless have IIR or UTPR obligations through foreign parents, intermediate parents or subsidiaries. "The UAE has no IIR" is not the same as "the group has no IIR exposure."
The OECD Pillar Two implementation hub provides the Model Rules, administrative guidance, safe harbours and implementation materials. The OECD Central Record should be checked for legislation with transitional qualified status.
When is the GloBE Information Return due globally?
The general GloBE framework uses a 15-month filing period after the end of the reporting fiscal year and an 18-month period for the transition year. For many groups first in scope for a fiscal year ending 31 December 2024, the initial 18-month date was 30 June 2026.
However, the group should not assume that every local filing follows only the general GIR timing. Domestic law may require earlier registrations, notifications, tax returns or payments. The transition year can also depend on when the group first becomes subject to a qualified IIR, UTPR or domestic minimum tax in the relevant context.
The OECD GloBE Information Return published in January 2025 defines the standard information architecture. The OECD GIR XML Schema supports electronic preparation and exchange.
Does central GIR filing remove local obligations?
Not automatically. Central filing can discharge a local GIR obligation where the relevant conditions are met, including an effective qualifying competent-authority agreement and timely exchange. The local entity may still need to notify its tax authority of the ultimate parent or designated filing entity and provide identifying details by the local deadline.
QDMTT returns and payments are domestic obligations and usually remain local. A group may therefore have one global GIR dataset, dozens of local notifications and multiple domestic minimum-tax returns generated from the same calculations.
The calendar should include a "central filing reliance" field with the filing jurisdiction, filing entity, exchange relationship, notification requirement, evidence owner and fallback action if exchange conditions are not satisfied.
Which non-UAE official resources should be monitored?
The group should use each tax authority's official page rather than relying only on global summaries. Examples include the UK Government's Multinational Top-up Tax and Domestic Top-up Tax collection and the Australian Taxation Office's global and domestic minimum tax guidance.
For EU entities, the EU Directive provides the common framework, but national registration, notification, return and payment rules must still be checked in each Member State. An OECD qualified-status listing does not replace domestic compliance guidance.
Every calendar entry should link directly to the law, tax-authority guide or filing instruction used. Secondary newsletters can help identify changes, but the final due date should be verified against a primary source.
What dependencies should sit behind each filing date?
A statutory deadline is the final node in a longer process. The operating calendar should work backward through:
-
legal-entity and scope confirmation.
-
financial close and consolidation data availability.
-
CbCR completion and safe-harbour screening.
-
current and deferred-tax data collection.
-
payroll and tangible-asset data for the SBIE.
-
jurisdictional calculation and tax-provision review.
-
election and filing-entity approval.
-
GIR/P2IR data validation.
-
domestic return preparation and payment approval.
-
submission, receipt retention and post-filing reconciliation.
If the return is due on 30 June, the internal deadline should not also be 30 June. Treasury may need days to arrange a material payment, while signatories and boards may need a defined review window.
How should the calendar be governed?
One master version
Maintain one group calendar with controlled access, version history and a named global owner. Local teams should update assigned fields rather than maintain disconnected calendars that are consolidated only near the deadline.
Primary-source evidence
Each due date should include the legal source, article or official guide, the date last checked and the reviewer. Save the source or citation where appropriate so the group can explain why it relied on the date.
Clear responsibility
Use a RACI covering the ultimate parent, local constituent entities, DLE, DDFE, finance, tax provision, treasury, legal and advisers. A company name alone is insufficient; assign a responsible person and backup.
Automated alerts with human review
Set alerts at 180, 120, 90, 60, 30 and 10 days according to risk. Automation should prompt review, not replace legal verification. Escalate any item with an unresolved filing entity, missing portal access or unconfirmed exchange condition.
Quarterly refresh and event-driven updates
Review at least quarterly. Update immediately after new legislation, a qualified-status change, acquisition, disposal, entity creation, liquidation, fiscal-year change or entry into a new country.
A practical 2026-2027 action plan for UAE groups
September-October 2026
Confirm the FY2025 scope and every UAE entity. Decide the registration approach, prepare DLE/DDFE governance and complete the data gap assessment. Calendar the transitional 30 November registration date where applicable.
By 30 November 2026
Complete Top-up Tax registration for entities within the transitional category. Retain application receipts, authorisations and the represented-entity schedule.
December 2026-February 2027
Close the FY2025 GloBE calculations, finalise safe-harbour elections, reconcile CbCR and populate the P2IR dataset. Confirm whether UAE filing or foreign-filer notification applies.
By 31 March 2027
File the P2IR or required notification for the FY2025 calendar year, subject to the group's facts and current filing instructions. Retain validation and submission evidence.
April-June 2027
Finalise the UAE Top-up Tax Return, allocation, sign-off and payment funding. Reconcile any changes made after the information-return cut-off.
By 30 June 2027
File the transition-year Top-up Tax Return and pay the UAE liability for the calendar-year illustration. Begin the FY2026 process using the lessons from year one rather than waiting for the next statutory date.
Frequently asked questions
What is the UAE DMTT registration deadline for a calendar-year group?
Where the first in-scope fiscal year ended on 31 December 2025, the transitional rule generally sets 30 November 2026 as the registration deadline.
When is the FY2025 UAE Pillar Two Information Return due?
For a reporting fiscal year ending 31 December 2025, the 15-month deadline generally falls on 31 March 2027. The group's filing or notification route must be confirmed under the current UAE rules.
When is the first UAE Top-up Tax Return due?
For a calendar-year group with FY2025 as its transition year, the 18-month period generally produces a 30 June 2027 deadline. Payment is due by the return deadline.
Is the P2IR deadline extended to 18 months in the transition year?
The UAE P2IR deadline should be calendared separately at 15 months under Article 15.4. The 18-month transition-year period relates to the first Top-up Tax Return, not automatically to the P2IR.
Does every UAE entity file its own P2IR?
Each relevant entity has a filing responsibility unless a valid central or designated local filing arrangement applies. Ministerial Decision No. 133 of 2026 should be used to determine the responsible filer.
Does central GIR filing remove the UAE DMTT return?
No. Central GIR filing or exchange can address the information-return obligation where conditions are met, but the UAE Top-up Tax Return and payment remain domestic obligations.
How often should a global Pillar Two calendar be updated?
At least quarterly and whenever the group enters a new jurisdiction, changes its fiscal year or structure, or a country changes legislation, filing mechanics or qualified status.
What is the biggest Pillar Two calendar mistake?
Treating registration, the information return, local notifications, the domestic tax return and payment as one deadline. They are separate obligations with different owners and dependencies.
Primary sources and further reading
How SBC Tax Consulting can help
SBC's international tax and corporate tax teams can support global calendar design, UAE registration, P2IR governance and DMTT filings. We map DLE and DDFE roles, work backward from the 31 March 2027 and 30 June 2027 dates, and keep the calendar aligned with data readiness. Contact SBC for a deadline review tailored to the group's year-end and footprint.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.