The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, setting out which entities must file the Pillar Two Information Return with the Federal Tax Authority under the UAE’s Top-up Tax regime for Fiscal Years starting on or after 1 January 2025.
The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026 setting out the entities required to file the Pillar Two Information Return under Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
The Decision forms part of the UAE’s implementation of the Pillar Two requirements and sets out reporting obligations for multinational enterprises operating in the UAE under the UAE’s Top-up Tax regime. It supports 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 Pillar Two Information Return may be filed 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.
The Decision issued on 25 August 2026.
Earlier, FTA issued Federal Tax Authority Decision No. 12 of 2026, establishing the registration, deregistration and notification requirements for entities subject to the domestic Top-up Tax under Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
