Website Last updated:

May 15, 2026

Article 12 establishes joint and several liability for Top-up Tax obligations. Within a Domestic Main Group, Domestic Minority-owned Subgroup, or for Reverse Hybrid Entities, all members are collectively responsible for the full tax amount. Similarly, members of a Domestic JV Group share joint liability. For entities that are not legal persons, partners or beneficiaries are liable to the extent of their ownership interests. This provision ensures that the UAE Federal Tax Authority has multiple avenues for the recovery of Top-up Tax liabilities from group members.

Article 12 - Joint and Several Liability

12.1 All Constituent Entities of a Domestic Main Group and Domestic Minority- owned Sub-Group located in the UAE and all Reverse Hybrid Entities referred to in Article 2.1(c) shall be jointly and severally liable for the full amount of the Top-up Tax attributable to members of those Groups and to the Reverse Hybrid Entities.

12.2 All Joint Ventures and JV Subsidiaries of a Domestic JV Group located in the UAE shall be jointly and severally liable for the full amount of the Top-up Tax attributable to members of that Domestic JV Group.

12.3 Any partner, beneficiary or any other person who holds an Ownership Interest in a Constituent Entity that is not a legal person, that are created under the laws of the UAE and that is required to pay the Top-up Tax in accordance with Article 2.1 shall be jointly and severally liable to pay the Top- up Tax of that Constituent Entity to the extent of its Ownership Interests in that Entity.