The UAE has introduced new tax reporting requirements for certain multinational enterprise (MNE) groups operating in the country. Ministerial Decision No. 133 of 2026 clarifies which UAE-based entities must file the Pillar Two Information Return with the Federal Tax Authority (FTA).
The decision forms part of the UAE's implementation of the Pillar Two Global Anti-Base Erosion (GloBE) Rules and the UAE Top-up Tax framework established under Cabinet Decision No. 142 of 2024. The reporting requirements apply to fiscal years beginning on or after 1 January 2025.
For multinational companies, this means that understanding the group's UAE entities, reporting responsibilities and financial data is becoming increasingly important. The new rules are focused on tax transparency and reporting, and businesses should not confuse the information return with the separate question of whether Top-up Tax is actually payable.
What are the UAE's New Tax Reporting Rules?
Ministerial Decision No. 133 of 2026 specifies the entities required to file the Pillar Two Information Return with the FTA. It was issued as part of the UAE's continued implementation of the Pillar Two framework and provides greater clarity on which entities are responsible for reporting.
The UAE's Pillar Two framework is aligned with the OECD/G20 Inclusive Framework's GloBE Rules. At a broad level, Pillar Two is designed to establish a global minimum tax framework for large multinational groups.
The UAE introduced its Domestic Minimum Top-up Tax through Cabinet Decision No. 142 of 2024. That framework applies to Constituent Entities of MNE Groups that meet the relevant global revenue conditions, including the EUR 750 million threshold under the UAE's Top-up Tax rules.
Ministerial Decision No. 133 of 2026 does not itself create a new corporate tax rate. Instead, it clarifies the filing obligations connected with the existing Pillar Two and Top-up Tax framework.
Who Needs to File the Pillar Two Information Return?
The decision identifies several categories of UAE-based entities that may have a Pillar Two Information Return filing obligation.
These include:
- Constituent Entities located in the UAE, except Investment Entities.
- Joint Ventures (JVs) located in the UAE.
- JV Subsidiaries located in the UAE.
- Certain Stateless Constituent Entities that are Reverse Hybrid Entities created under UAE law.
A Constituent Entity is generally an entity or permanent establishment that forms part of an MNE Group for Pillar Two purposes. Therefore, businesses should not assess the reporting obligation based only on whether an individual UAE company is large or small.
The wider group structure, consolidation position and status under the GloBE Rules need to be considered.
There are also circumstances where a UAE entity may not need to submit the return directly because the reporting obligation can be satisfied through another eligible filing arrangement. Businesses should therefore review the rules for their particular group before assuming that every UAE entity must submit a separate return.
What is the Pillar Two Information Return?
The Pillar Two Information Return (PTIR) is a detailed tax information return used to provide the information needed to administer the GloBE Rules.
It is not simply another standard UAE Corporate Tax return. The information required can cover the group's structure, the entities included in the group, jurisdictional tax information and data used in determining effective tax rates and Top-up Tax.
Under Cabinet Decision No. 142 of 2024, the return is based on the OECD/G20 Inclusive Framework's standard template and can include information such as:
- Identification and tax details of Constituent Entities.
- The overall corporate structure of the MNE Group.
- Controlling interests between group entities.
- Information needed to calculate the effective tax rate for each jurisdiction.
- Information needed to determine Top-up Tax.
- Relevant elections made under the Pillar Two rules.
- Other information required under the Pillar Two Implementation Framework.
This makes the quality of accounting and tax data particularly important. A multinational group may need information from different entities, jurisdictions and financial systems before the return can be prepared accurately.
When Does the New Reporting Requirement Apply?
Ministerial Decision No. 133 of 2026 applies to fiscal years beginning on or after 1 January 2025.
This is important because the decision was issued in 2026, but its scope reaches back to fiscal years beginning from 1 January 2025.
The filing deadline for the Pillar Two Information Return is generally 15 months after the last day of the relevant Reporting Fiscal Year under Article 15 of Cabinet Decision No. 142 of 2024. A transitional extension to 18 months applies for the first year under the Top-up Tax framework.
For example, a group with a fiscal year ending on 31 December 2025 should pay close attention to the applicable first-year and transitional filing rules rather than assuming that the ordinary 15-month period applies without exception.
Reporting Does Not Automatically Mean Top-up Tax Is Payable
It is also important to separate reporting obligations from tax liability.
A company may fall within the reporting framework and still need to perform the relevant Pillar Two calculations before determining whether Top-up Tax is payable. The information return supports the administration of the framework; it should not be treated as a simple calculation of the UAE's standard Corporate Tax liability.
Can a Designated Local Entity File on Behalf of the Group?
Yes. The UAE rules allow a Designated Local Entity (DLE) to file the Pillar Two Information Return on behalf of other relevant UAE entities within the group.
This provides multinational groups with an option to centralise their UAE reporting rather than requiring each relevant entity to manage the filing separately. The Ministry of Finance has specifically confirmed that the return may be filed either directly by the relevant Constituent Entity, Joint Venture or JV Subsidiary, or by a Designated Local Entity on its behalf.
For groups with several UAE subsidiaries, branches or other relevant entities, centralising the reporting process can make information gathering and internal coordination more structured.
However, appointing one entity to file does not remove the need for accurate information from the other entities represented in the return. The group should establish clear responsibilities for collecting, reviewing and approving the required data.
Which Entities are Excluded From the Filing Requirement?
One important exclusion under Ministerial Decision No. 133 of 2026 relates to Investment Entities. The Ministry of Finance states that Constituent Entities located in the UAE are subject to the filing requirement except for Investment Entities.
Businesses should be careful not to interpret this exclusion too broadly. Whether an entity qualifies as an Investment Entity depends on the definitions and conditions under the Pillar Two framework.
There can also be situations where a UAE filing obligation is discharged through an eligible filing made by an Ultimate Parent Entity or Designated Filing Entity in another jurisdiction under an applicable qualifying information-exchange arrangement. In such cases, the UAE group's notification requirements still need to be considered.
Therefore, businesses should assess their exact group structure and filing position instead of assuming that an entity is excluded simply because it is part of a larger multinational group.
What Information Do Multinational Companies Need to Prepare?
Pillar Two reporting can require significantly more information than a normal Corporate Tax compliance exercise.
The exact data requirements depend on the group's structure and circumstances, but businesses should generally be prepared to collect and reconcile information covering:
- Group structure and entity details:
Information about the Ultimate Parent Entity, Constituent Entities, ownership interests, jurisdictions and relevant entity classifications. - Financial information:
Financial statement data and other accounting information needed for the GloBE calculations. - Tax information:
Covered taxes and other tax-related data required to determine the effective tax rate for relevant jurisdictions. - GloBE calculations:
Information used to determine GloBE income or loss, effective tax rates and any applicable Top-up Tax. - Elections and adjustments:
Details of elections, adjustments, safe-harbour positions and other relevant treatments under the applicable Pillar Two rules. - Supporting records:
Accounting records, tax calculations, group structure documents and other evidence supporting the information reported to the FTA.
The UAE's Pillar Two framework requires the information return to follow the OECD/G20 standard template and applicable Pillar Two Implementation Framework requirements.
What Should UAE Multinational Companies Do Now?
Businesses that may fall within the Pillar Two framework should start by determining whether their group is within scope and identifying all relevant UAE entities.
A practical review can include the following steps:
- Determine whether the MNE Group falls within the Pillar Two framework.
Review the group's consolidated revenue and other scope conditions. - Map the UAE entities.
Identify Constituent Entities, Joint Ventures, JV Subsidiaries and any other entities that may have reporting obligations. - Review the fiscal year.
Confirm when the relevant fiscal year began and determine the applicable filing deadline. - Determine who will file.
Assess whether each entity will file individually, whether a Designated Local Entity will file for UAE entities, or whether an eligible foreign filing arrangement applies. - Collect financial and tax data.
Bring together information from accounting, tax, finance and group reporting systems. - Reconcile the information.
Make sure figures used for Pillar Two reporting are consistent with the underlying financial and tax records. - Maintain supporting documentation.
Keep records that explain and support the calculations and information submitted.
The FTA continues to develop and publish guidance around UAE tax compliance, while the Ministry of Finance maintains the relevant financial legislation. Businesses should therefore monitor official updates rather than relying only on older Pillar Two procedures.
Potential Risks of Non-Compliance
For multinational groups, Pillar Two compliance is not simply about submitting a form. The quality and consistency of the information behind the return are also important.
Late or incorrect reporting can create compliance issues and may require additional explanations, corrections or interaction with the FTA. Inaccurate information can also create inconsistencies between the group's financial statements, tax calculations and information submitted under the Pillar Two framework.
Businesses should also distinguish between penalties that may apply specifically to Pillar Two registration, notification, return or other compliance obligations and the general consequences of inaccurate tax reporting. The applicable rules can depend on the type of non-compliance and the relevant legislation.
For this reason, multinational groups should not wait until the filing deadline to identify missing data or unclear responsibilities. Early preparation gives finance and tax teams more time to reconcile information and resolve inconsistencies.
How Can Businesses Prepare for UAE Pillar Two Reporting?
A structured Pillar Two readiness assessment can help businesses understand what needs to be done before the first relevant filing.
The process can begin with a review of the group's ownership structure and UAE presence, followed by an assessment of accounting systems, tax data and existing reporting procedures.
Businesses should pay particular attention to whether information from different UAE entities can be collected in a consistent format. Where group companies use different accounting systems or reporting periods, additional reconciliation may be required.
It is also useful to establish clear internal responsibilities. Finance teams may hold the accounting data, tax teams may handle tax calculations, and group-level teams may control ownership and consolidation information. Bringing these sources together early can reduce last-minute reporting problems.
Where the group does not have sufficient internal expertise, professional UAE Corporate Tax and Pillar Two compliance support can help with scope assessment, data preparation, calculations, reporting and documentation.
Conclusion
The UAE's Ministerial Decision No. 133 of 2026 provides greater clarity on who must file the Pillar Two Information Return under the country's Top-up Tax framework. The requirements apply to relevant fiscal years beginning on or after 1 January 2025 and cover UAE Constituent Entities, Joint Ventures, JV Subsidiaries and certain Stateless Constituent Entities, subject to the stated exclusions and filing alternatives.
For multinational companies, the key priority is to understand the group's structure, identify the relevant UAE entities and establish how the Pillar Two information will be collected, reviewed and filed. Accurate financial and tax data, clear internal responsibilities and proper supporting documentation can make the reporting process more manageable.
Businesses that may fall within the UAE Pillar Two framework should assess their obligations early and consider professional UAE Corporate Tax and Pillar Two compliance support where the rules or group structure are complex.
Frequently Asked Questions
- What is the UAE Pillar Two Information Return?
The Pillar Two Information Return is a tax information return used to provide information required to administer the UAE's Pillar Two and Top-up Tax framework. It includes information about the MNE Group's structure and data needed for GloBE-related calculations and reporting.
- Who is required to file the Pillar Two Information Return in the UAE?
Under Ministerial Decision No. 133 of 2026, the filing obligation generally covers each UAE Constituent Entity other than an Investment Entity, each UAE Joint Venture and JV Subsidiary, and certain Stateless Constituent Entities that are Reverse Hybrid Entities created under UAE law, subject to the applicable filing alternatives and exceptions.
- When do the new UAE multinational tax reporting rules apply?
Ministerial Decision No. 133 of 2026 applies to fiscal years beginning on or after 1 January 2025. The relevant filing deadline is generally linked to the end of the Reporting Fiscal Year, with the applicable transitional rule for the first year.
- Can a Designated Local Entity file the return for other UAE entities?
Yes. The rules allow a Designated Local Entity to file the Pillar Two Information Return on behalf of relevant UAE Constituent Entities, Joint Ventures or JV Subsidiaries. This allows a multinational group to centralise its UAE reporting process.
- Are Investment Entities required to file the Pillar Two Information Return?
Investment Entities are specifically excluded from the filing obligation applicable to UAE Constituent Entities under Ministerial Decision No. 133 of 2026. However, businesses should first confirm that the entity meets the relevant Pillar Two definition of an Investment Entity.
- What happens if a multinational company fails to meet the reporting requirements?
The consequences depend on the specific compliance failure and the applicable UAE tax legislation. Late or inaccurate reporting can create compliance issues and may expose the business to penalties or additional FTA scrutiny where applicable. MNE groups should therefore assess their filing, notification and record-keeping obligations separately and maintain evidence supporting the information reported.
