FTA Top-up Tax Guide: Scope and Registration (TTGREG1), August 2026

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Example 11: Testing revenue in two of four preceding Fiscal Years Company B is located in the UAE and is the UPE of an MNE Group as shown in the diagram below. 28 Article 1.1.1 of the QDMTT Legislation. 29 Paragraph 6 of the Commentary on Article 1 of the GloBE Rules. 30 Paragraph 10.2 of the Commentary on Article 1 of the GloBE Rules. UAE Company B Company O Company H Company A Company S Jurisdiction O Jurisdiction H Jurisdiction A UAE = Consolidated on a line-by-line basis According to the Consolidated Financial Statements of Company B, the consolidated revenue is as follows: FY 2021 FY 2022 FY 2023 FY 2024 FY 2025 EUR 720 million EUR 770 million EUR 710 million EUR 800 million EUR 720 million To assess whether the MNE Group is in scope for the QDMTT Legislation in Fiscal Year 2025, the consolidated revenue in the previous four Fiscal Years should be considered. The amount of revenue of the tested Fiscal Year (2025) is not relevant. The consolidated revenue is above the EUR 750 million threshold in two of four prior Fiscal Years, namely in 2024 and in 2022. Accordingly, the MNE Group satisfies the consolidated revenue threshold test, and is in scope for the QDMTT Legislation in Fiscal Year 2025.

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Example 14: Fiscal Year shorter than 12 months Group A followed the Gregorian calendar year as its Fiscal Year. However, in the year 2024, it decided to change its Fiscal Year from 1 October to 30 September. Hence, for 2024, the Consolidated Financial Statements is prepared for the period from 1 January 2024 to 30 September 2024. Accordingly, the Fiscal Year 2024 is a short period of 9 months. 37 Paragraph 14 of the Commentary on Article 1 of the GloBE Rules. 38 Definition of Fiscal Year in Article 18.1 of the QDMTT Legislation. 39 Article 1.1.2 of the QDMTT Legislation. The QDMTT Legislation applies to Fiscal Years commencing on or after 1 January 2025. Accordingly, the Group is evaluating whether it is within scope of the QDMTT Legislation for its first Fiscal Year commencing on or after 1 January 2025, i.e. the tested Fiscal Year in this case will be 1 October 2025 to 30 September 2026. In this regard, the consolidated revenue of Group A for the previous four Fiscal Years is as follows: Fiscal Year 2022 2023 2024 (1 January 2024 to 30 September 2024) 2025 (1 October 2024 to 30 September 2025) Amount of consolidated revenue (in EUR millions) 400 600 550 Length of period 12 months 12 months 9 months 760 12 months For the purposes of determining whether the Fiscal Year beginning on 1 October 2025 (tested Fiscal Year) meets the consolidated revenue threshold, the Group has to test the consolidated revenue for the previous four Fiscal Years. However, since the Fiscal Year beginning in January 2024 is less than 12 months (i.e. 9 months), the consolidated revenue threshold needs to be adjusted proportionally. Accordingly, the consolidated revenue threshold for the Fiscal Year beginning in January 2024 is adjusted to reflect the nine-month period (EUR 750 million x [9/12] = EUR 562.5 million). In this respect, the consolidated revenue threshold for that Fiscal Year has not been met since EUR 550 is below EUR 562.5 million. Consequently, Group A does not satisfy the consolidated revenue threshold condition for the 2025 Fiscal Year as the consolidated revenue threshold was satisfied only in respect of the 2025 Fiscal Year, i.e. only in one of the preceding four Fiscal Years.

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Example 15: Currency conversion – from AED Group P is an MNE Group headquartered in the UAE, with subsidiaries in Jurisdictions A, B and C. The Consolidated Financial Statements of the MNE Group are presented in AED. However, the QDMTT Legislation sets the consolidated revenue threshold in EUR. To determine whether Group P is in scope in Fiscal Year 2025, the consolidated revenue for the Fiscal Years 2021 to 2024 must be converted from AED to EUR. Given that AED is not part of the standard European Central Bank reference rate set, the exchange rate used for the conversion should be based on the average of the daily reference rates of December prior to the commencement of the relevant Fiscal Year, as quoted by the Central Bank of the UAE. Currency AED Exchange Rate FY 2021 2,700 million 4.47 Consolidated Revenue FY 2022 FY 2023 3,500 million 2,800 million 4.15 3.89 FY 2024 3,200 million 4.01 40 Article 10.6 of the QDMTT Legislation. EUR (average of the daily reference rates of December 2020) 604 million (average of the daily reference rates of December 2021) 843 million (average of the daily reference rates of December 2022) 720 million (average of the daily reference rates of December 2023) 798 million Since the revenue of Group P exceeded the EUR 750 million threshold in Fiscal Years 2022 and 2024, i.e. two of the preceding four Fiscal Years, Group P will be in scope of the QDMTT Legislation in Fiscal Year 2025.