Website Last updated:

May 15, 2026

Article 8 governs administrative compliance and temporary relief. It mandates the filing of a Top-up Tax Return with the FTA within 15 to 18 months of the fiscal year-end. Significantly, it introduces the Transitional CbCR Safe Harbour, which can reduce Top-up Tax to zero for entities meeting specific revenue, ETR, or profit tests during the transition period. The article also provides for 'Simplified Calculations' for non-material entities and outlines the circumstances under which the FTA may disapply safe harbours, ensuring a balance between administrative ease and robust enforcement of the GloBE rules.

Article 8 - Filing of Top-Up Tax Return and Safe Harbours

Article 8.1 Top-up Tax Return Filing

8.1.1 Each Constituent Entity, Joint Venture and JV Subsidiary located in the UAE shall file a Top-up Tax Return with the Federal Tax Authority. The return may be filed by either the Constituent Entity, Joint Venture or JV Subsidiary itself or by a Domestic Designated Filing Entity on its behalf.

8.1.2 The Top-up Tax Return shall be filed in the manner specified by the Federal Tax Authority no later than 15 months after the last day of the Reporting Fiscal Year or 18 months after the last day of the Reporting Fiscal Year that is the first Transition Year of any Constituent Entity of the MNE Group.

8.1.3 The Top-up Tax Return developed by the Federal Tax Authority shall require the equivalent information and reporting requirements set out in the Pillar Two Information Return. The Constituent Entities, Joint Ventures, JV Subsidiaries or Domestic Designated Filing Entity may choose to apply the simplified Jurisdictional reporting framework provided in the Pillar Two Information Return.

Article 8.2. Safe Harbours

8.2.1 Transitional CBCR Safe Harbour

8.2.1.1 During the Transition Period, at the election of the Filing Constituent Entity, and notwithstanding Article 5, the Jurisdictional Top-up Tax of the UAE shall be deemed to be zero for a Fiscal Year if:

(a) the MNE Group reports Total Revenue of less than EUR 10 million and Profit (Loss) before Income Tax of less than EUR 1 million in the UAE on its Qualified CbC Report for the Fiscal Year;

(b) the MNE Group has a Simplified Effective Tax Rate that is equal to or greater than the Transition Rate in the UAE for the Fiscal Year; or

(c) the MNE Group’s Profit (Loss) before Income Tax in the UAE is equal to or less than the Substance-based Income Exclusion amount as calculated under Articles 5.3 and 9.2, for entities reported in the UAE in the Country- by-Country Report.

8.2.1.2Article 8.2.1.1 shall apply to the Joint Venture and JV Subsidiaries as if they were Constituent Entities of a separate MNE Group, except that the Pillar Two Income or Loss and Total Revenue would be the ones reported in their Qualified Financial Statements.

8.2.1.3 The following adjustments shall be made for purposes of Article 8.2.1.1: