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The Ministry of Finance has issued Ministerial Decision No. 133 of 2026 on the entities required to file the Pillar Two Information Return for the purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
The Ministerial Decision forms part of the UAE’s continued implementation of the Pillar Two requirements and reaffirms the country’s commitment to enhancing international tax transparency, while providing greater tax certainty and clarity for multinational enterprises regarding their reporting obligations.
The Decision sets out the filing obligations relating to the Pillar Two Information Return for multinational enterprises operating in the UAE under the UAE’s Top-up Tax regime, supporting the consistent implementation of the Pillar Two Global Anti-Base Erosion (GloBE) Rules of the OECD/G20 Inclusive Framework.
Under the Decision, the following entities are required to file a Pillar Two Information Return with the Federal Tax Authority: each Constituent Entity, excluding any Investment Entity, located in the UAE; each Joint Venture and JV Subsidiary located in the UAE; and each Stateless Constituent Entity that is a Reverse Hybrid Entity created in accordance with the laws of the UAE.
The Decision also permits the Pillar Two Information Return to be filed either directly by the Constituent Entity, Joint Venture or JV Subsidiary, or by the Designated Local Entity on its behalf.
The Ministerial Decision applies to Fiscal Years starting on or after 1 January 2025.
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