The UAE has clarified which entities must file a Pillar Two Information Return under its Top-up Tax regime.
Ministerial Decision No. 133 of 2026 places the filing responsibility on certain UAE entities that belong to multinational enterprise groups. The rules apply to financial years starting on or after 1 January 2025.
For affected groups, the decision answers an important question: which entity is responsible for submitting the return to the Federal Tax Authority?
It also allows some groups to satisfy the requirement through a parent or designated filing entity in another jurisdiction. That option comes with conditions, however, and the UAE entities may still have to notify the Federal Tax Authority.
This article explains the new UAE Pillar Two tax reporting rules, who they affect and what multinational groups should do next.
What is Pillar Two?
Pillar Two is part of the international tax framework developed by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting.
In broad terms, the rules seek to ensure that large multinational groups pay an effective tax rate of at least 15% in each jurisdiction where they operate. If the effective rate in a jurisdiction falls below that level, a Top-up Tax may apply.
The UAE introduced a Domestic Minimum Top-up Tax through Cabinet Decision No. 142 of 2024. It applies to constituent entities of multinational groups with consolidated global revenue of at least EUR 750 million in two or more of the four financial years immediately before the relevant financial year.
The UAE Domestic Minimum Top-up Tax took effect for financial years beginning on or after 1 January 2025. It follows the OECD’s Global Anti-Base Erosion rules, commonly called the GloBE Rules.
Pillar Two is separate from the UAE’s standard corporate tax regime. A company may therefore need to consider ordinary corporate tax requirements as well as separate registration, calculation and reporting duties under the Top-up Tax rules.
What changed under Ministerial Decision No. 133 of 2026?
Cabinet Decision No. 142 of 2024 established the wider UAE Top-up Tax framework. Article 15 stated that entities specified in a later ministerial decision would have to file the Pillar Two Information Return.
Ministerial Decision No. 133 of 2026 provides that missing detail.
Issued on 3 August 2026, the decision identifies the UAE entities responsible for filing. It also explains when another entity may file on their behalf and when a UAE filing may be replaced by a return submitted in another qualifying jurisdiction.
The Ministry of Finance publicly announced the decision on 25 August 2026. According to the Ministry, it applies to financial years starting on or after 1 January 2025.
Which UAE entities must file a Pillar Two Information Return?
The decision identifies three categories of filing entities.
First, each constituent entity located in the UAE must file, unless it is an investment entity.
A constituent entity is generally an entity or permanent establishment included within an in-scope multinational group. The precise classification depends on the definitions and consolidation rules in Cabinet Decision No. 142 of 2024.
Second, each joint venture and joint venture subsidiary located in the UAE must file.
This category matters because a joint venture may fall within the Pillar Two framework even if it is not treated in the same way as an ordinary constituent entity in the group’s consolidated financial statements.
Third, the requirement applies to each stateless constituent entity that is a reverse hybrid entity created under UAE law.
Reverse hybrid structures can be difficult to classify because different jurisdictions may treat the same entity differently for tax purposes. Multinational groups with partnerships, transparent entities or similar arrangements should check whether any UAE-created entity meets this definition.
Investment entities are specifically excluded from the first filing category. Businesses should not assume that every fund, holding vehicle or investment-related company qualifies for that exclusion. “Investment Entity” is a defined Pillar Two term, so the legal conditions must be tested.
Can one UAE entity file for the group?
Ministerial Decision No. 133 allows a designated local entity to submit the Pillar Two Information Return on behalf of a UAE constituent entity, joint venture or joint venture subsidiary.
This can reduce duplicate work where a group has several entities in the UAE. Instead of preparing separate submissions independently, the group can centralise the filing through one designated UAE entity.
Centralisation does not remove the need for accurate entity-level information. The designated local entity will still need data from the companies it represents, including ownership details, tax identification numbers and information used in the group’s Pillar Two calculations.
Each entity should also confirm that the group has formally assigned responsibility. Informal assumptions between finance teams create obvious risks, particularly where several subsidiaries use different accountants, systems or reporting calendars.
When is a UAE entity not required to file the full return locally?
A UAE constituent entity, joint venture or joint venture subsidiary may be relieved from filing the Pillar Two Information Return directly with the Federal Tax Authority if a compliant return is filed by either:
- the ultimate parent entity in another jurisdiction; or
- a designated filing entity in another jurisdiction.
For this exception to apply, the other jurisdiction must have a Qualifying Competent Authority Agreement in effect with the UAE for the relevant reporting financial year.
That condition is important. A multinational group cannot rely solely on the fact that its parent company files a return overseas. It must confirm that the filing jurisdiction has the required information-exchange arrangement with the UAE for the period concerned.
The overseas return must also meet the requirements of Article 15 of Cabinet Decision No. 142 of 2024. An incomplete submission or a filing made under a regime that does not qualify may not remove the UAE entity’s local obligation.
A notification may still be required
Relief from filing the full return does not necessarily mean that the UAE entity has nothing to submit.
When an ultimate parent entity or designated filing entity submits the return in another qualifying jurisdiction, the UAE entity or its designated local entity must notify the Federal Tax Authority. The notification must identify the entity or entities filing the Pillar Two Information Return and state where they are located.
Groups should build this notification into their compliance timetable. Otherwise, a team may correctly arrange the overseas filing but overlook the separate UAE notification.
The filing position should be documented as well. The UAE entity should retain evidence of the filing entity’s identity, its jurisdiction, the applicable competent authority agreement and the group’s decision to rely on the overseas return.
What information does the return contain?
The Pillar Two Information Return is much more detailed than an ordinary company information form.
Under Article 15 of Cabinet Decision No. 142 of 2024, it follows the standard template published by the OECD/G20 Inclusive Framework, as amended from time to time.
The required information includes the identities of the group’s constituent entities, their tax identification numbers where available, their locations and their status under the Pillar Two rules.
The return also covers the group’s corporate and ownership structure. This includes controlling interests held by one group entity in another.
More demanding sections deal with the figures needed to calculate the group’s jurisdictional effective tax rate and any Top-up Tax. The return may also include calculations for joint venture groups, the allocation of tax under relevant Pillar Two charging rules, and a record of elections made by the group.
This requires coordination between tax, accounting and legal teams. The information may sit across consolidation systems, local ledgers, corporate records and tax-return workpapers. It is rarely available from one report.
What is the filing deadline?
Cabinet Decision No. 142 of 2024 states that the Pillar Two Information Return and the related notifications must be filed no later than 15 months after the final day of the reporting financial year.
For example, if an in-scope group has a reporting financial year ending on 31 December 2025, the standard 15-month period ends on 31 March 2027.
Groups should confirm the deadline that applies to their circumstances rather than treating this example as universal. Financial year-ends vary, and further decisions or applicable transitional provisions may affect the final compliance timetable.
It is also worth separating the Pillar Two deadline from the ordinary UAE Corporate Tax deadline. The two regimes do not necessarily follow the same filing schedule.
What should multinational groups do now?
The first step is to confirm whether the EUR 750 million revenue threshold is met. The test uses the consolidated revenue of the ultimate parent entity and looks at two of the four financial years immediately before the year being assessed.
Groups that meet the threshold should map every UAE entity, permanent establishment, joint venture and joint venture subsidiary. They should also review UAE-created transparent or hybrid entities rather than limiting the exercise to incorporated subsidiaries.
Next, the group needs to classify each entity under the GloBE Rules. This includes checking whether any entity qualifies as an investment entity or another excluded entity.
The filing model should then be agreed. A group may file through each local entity, appoint a designated local entity or rely on an overseas filing where the legal conditions are satisfied. The choice should be recorded clearly, with named owners and internal deadlines.
Data collection should begin well before the filing date. Groups may need to reconcile financial accounting figures, covered taxes, deferred tax balances, payroll information and the carrying value of tangible assets. Ownership changes and restructuring activity may also affect the calculation.
Finally, the group should compare its Pillar Two process with its existing UAE tax obligations. Registration, Top-up Tax returns, payments and the Pillar Two Information Return are connected, but they are not interchangeable.
Why early preparation matters
A group can have no Top-up Tax payable and still face reporting work.
Safe harbours, exclusions and other reliefs may reduce the amount due or simplify parts of the calculation. They do not automatically remove every filing or notification requirement. The group must first establish that the relevant conditions are met.
There is also a practical timing problem. Pillar Two reporting depends on information from several jurisdictions, but local finance teams may close their records at different speeds. Waiting until the filing deadline approaches leaves little time to investigate missing data or resolve differences between local accounts and the consolidated financial statements.
The most useful response is a dry run. Groups can test the entity list, decide where the return will be filed and identify the people responsible for each data point. That exercise usually exposes gaps much earlier than a formal return-preparation process.
How professional support can help
The new decision answers the question of who must file, but applying the rules still requires detailed work.
A Pillar Two review may involve checking whether the group meets the revenue threshold, classifying UAE entities, assessing the availability of filing relief and preparing the data needed for the return. Businesses may also need help coordinating the Pillar Two process with their ordinary UAE corporate tax obligations.
Professional UAE corporate tax services can help multinational groups establish a filing position, document their conclusions and prepare for their first reporting cycle.
Final takeaway
Ministerial Decision No. 133 of 2026 gives multinational groups a clearer filing framework.
UAE constituent entities, apart from investment entities, are generally within the filing rule. UAE joint ventures, JV subsidiaries and certain reverse hybrid entities are also covered. A designated local entity may file on their behalf, while an overseas parent or designated filing entity may satisfy the full-return requirement when the conditions for exchange with the UAE are met.
The decision applies to financial years starting on or after 1 January 2025. Groups that may fall within the EUR 750 million threshold should settle their entity classifications and filing arrangements now. The return may not be due immediately, but the information behind it takes time to assemble.
This article is intended for general information only and does not constitute tax or legal advice. Businesses should obtain advice based on their group structure, financial year and specific circumstances.
