The Federal Tax Authority updated the Corporate Tax Return portal on Emara Tax last week with new mandatory shareholding disclosure requirements. If you file by 30 September 2026, you will see them. And if you don’t prepare the right answers now, you’ll be scrambling in September.
This isn’t cosmetic. The new fields aren’t just administrative checkboxes. They are a direct signal that the UAE is integrating corporate tax compliance with Pillar Two/DMTT registration, transfer pricing reporting, and group-level transparency. Miss the alignment, and you’ll face clarification requests months after you file.
What Changed
The earlier Corporate Tax Return asked a single binary question: “Is your entity part of a Multinational Enterprise (MNE) Group?” Yes or No.
That’s gone. In its place, the FTA now requires four mandatory disclosures under the new “Shareholding Details” section:
- Name of the ultimate parent company — the entity at the top of your consolidated financial statements
- Country of tax residency of the ultimate parent — where that entity is tax resident
- Name of the immediate parent company — the entity that directly owns yours (or controls it)
- Country of tax residency of the immediate parent — where that entity files taxes
Two additional optional fields ask for:
- Tax identification / registration number of the ultimate parent
- Tax identification / registration number of the immediate parent
And one optional field asks for:
- Name of the MNE group (usually drawn from consolidated financial statements at ultimate parent level)
Why This Matters — The Pillar Two Connection
The terminology the FTA chose — “MNE group,” “ultimate parent,” “immediate parent” — is not accidental. These are concepts pulled directly from the OECD GloBE framework that powers Pillar Two.
The UAE’s Domestic Minimum Top-up Tax (DMTT), which became effective for fiscal years starting 1 January 2025, applies to any constituent entity within an MNE group if that group’s consolidated revenue exceeds EUR 750 million in at least two of the preceding four fiscal years.
The threshold is measured at ultimate parent level using consolidated financials.
The new Corporate Tax Return fields now capture exactly the data the FTA needs to cross-reference your filing with Pillar Two registrations. If you register for Pillar Two on Emara Tax, the same ultimate parent, immediate parent, and group structure data will flow across both platforms. If the two disclosures don’t match, the FTA will see it.
The Hidden Risk: Data Reconciliation
This is where most businesses will stumble.
Suppose you file your Corporate Tax Return in August and identify your ultimate parent as “Global Holdings Inc.” in the United States. Then in September, you register for Pillar Two and, because your group restructured in March, you list the ultimate parent as “Global Holdings II LLC” in Delaware.
Same group, different legal entity at the top due to a restructuring the FTA wasn’t yet aware of.
The two filings will now sit side-by-side in the FTA’s database, showing conflicting group structures. The authority will flag it. You’ll receive a clarification request. You’ll send an amendment. And your file will be marked as having required additional attention — exactly the kind of signaling that invites deeper audit scrutiny.
The solution is simple: map your group structure now, confirm the true ultimate parent under consolidation accounting principles, and ensure that same entity appears consistently across:
- Your 2025 consolidated financial statements
- Your Country-by-Country Reporting (if applicable)
- Your Pillar Two registration on Emara Tax
- Your Corporate Tax Return disclosure
For Standalone Entities and Individual Owners
One ambiguity remains: the FTA has marked the “ultimate parent” and “immediate parent” fields as mandatory, but many entities have no parent — they’re standalone, or they’re held by individuals rather than corporate entities.
The guidance hasn’t clarified whether “N/A” or a blank submission is acceptable in these cases. Until it does, the conservative approach is to contact the FTA in advance for clarification if your entity:
- Is a startup with no parent entity
- Is held directly by individual shareholders or a trust
- Is a joint venture with no clear controlling parent
Do not wait until you’re filing to discover that the portal rejects your submission.
What You Should Do Now — By August 15
- Pull your group’s consolidated financial statements for 2025 (or the most recent year available)
- Identify the ultimate parent entity — the highest-level company in your consolidated group, typically the one that prepares Group-level financial statements or files Pillar Two/CbCR returns
- Confirm its country of tax residency — where it files its own corporate tax return (usually based on incorporation or place of effective management)
- Obtain its tax identification number — the registration or ID number from that country’s tax authority (US EIN, UK Tax Reference, UAE TRN, etc.)
- Identify the immediate parent — the entity that directly owns or controls your business
- Repeat steps 3–4 for the immediate parent
- Reconcile against any DMTT or Pillar Two filings you’ve made (or plan to make) in the UAE or other jurisdictions
- Document the group structure — keep a clean org chart showing legal entities, ownership percentages, and jurisdictions. This will serve you when the FTA asks clarifying questions.
The Bigger Picture
This change is part of a larger maturation of the UAE Corporate Tax regime. The authority is moving from a standalone domestic filing exercise to a truly integrated system where:
- Corporate Tax Returns feed into Pillar Two registrations
- Transfer Pricing disclosures connect to group structure data
- Substance and function analyses tie back to shareholding and control
- Inconsistencies across filings are immediately visible
The quality of the group structure data you enter today will shape your compliance experience for years — not just this filing cycle.
Act Before the Rush
You have 70 days until 30 September 2026. The first 20 days (by 15 August) are the window to gather and reconcile this data without panic. The last 50 days will be the filing rush, when every business will be compressing final numbers, managing last-minute audits, and racing to meet the deadline.
Start the group reconciliation now. It takes three hours to get it right. It takes three weeks to fix it if you get it wrong.
FSH Financial Consultants assists UAE businesses with corporate tax return preparation, shareholding disclosures, Pillar Two registration alignment, and group structure reconciliation. Contact us to ensure your 2025 filings are coordinated and audit-ready.
Sources: Federal Tax Authority Corporate Tax Return Portal (Emara Tax); Cabinet Decision No. 142 of 2024 (DMTT); FTA Shareholding Details Guidance (July 2026); OECD GloBE Framework; Federal Decree-Law No. 47 of 2022 (UAE Corporate Tax Law).
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- Category: Corporate Tax
- Target audience: UAE business owners, CFOs, tax advisors
- Tone: Technical but accessible; action-oriented
- Call-to-action: Group structure reconciliation by 15 August