The UAE has issued Ministerial Decision No. 133 of 2026 setting out who must file the Pillar Two Information Return. Learn who is covered, what the rules require and when they apply.
01 October, 2026
UAE Pillar Two Information Return 2026: New Filing Requirements for Multinational Businesses
The UAE has introduced another important requirement as part of its implementation of the Pillar Two global minimum tax rules. The Ministry of Finance has issued Ministerial Decision No. 133 of 2026, which specifies the UAE entities required to file the Pillar Two Information Return with the Federal Tax Authority (FTA).
The decision applies to Fiscal Years starting on or after 1 January 2025 and provides greater clarity on which UAE entities within multinational groups are responsible for the filing.
But what exactly is the Pillar Two Information Return, which UAE businesses are affected, and how does it relate to the UAE's Domestic Minimum Top-up Tax?
What is the UAE Pillar Two Information Return?
The Pillar Two Information Return is part of the UAE's implementation of the OECD/G20 Global Anti-Base Erosion (GloBE) Rules.
It is important to distinguish the Information Return from the tax itself. The return is a reporting requirement under the UAE's Pillar Two regime. It provides tax authorities with information relevant to the application of the Top-up Tax rules.
The UAE's Pillar Two regime was established through Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises.
Under Article 15 of the Annexure to Cabinet Decision No. 142 of 2024, the Pillar Two Information Return forms part of the reporting requirements applicable to entities within the scope of the UAE Top-up Tax regime.
Why has the UAE introduced these requirements?
The UAE introduced its Domestic Minimum Top-up Tax (DMTT) as part of its implementation of the OECD/G20 Two-Pillar Solution.
The UAE DMTT applies to Constituent Entities that are members of multinational enterprise groups meeting the applicable revenue threshold. The relevant threshold is €750 million or more in annual global revenue in the consolidated financial statements of the Ultimate Parent Entity in at least two of the four financial years immediately preceding the relevant financial year.
The UAE DMTT applies to financial years starting on or after 1 January 2025.
The UAE Ministry of Finance has stated that the DMTT is closely aligned with the OECD GloBE Model Rules, Commentary and Administrative Guidance.
What does Ministerial Decision No. 133 of 2026 change?
Ministerial Decision No. 133 of 2026 specifically addresses the question of which UAE entities are required to file the Pillar Two Information Return.
According to the Ministry of Finance, the following entities are required to file with the FTA, subject to the applicable provisions:
Each Constituent Entity located in the UAE, excluding an Investment Entity;
Each Joint Venture and JV Subsidiary located in the UAE; and
Each Stateless Constituent Entity that is a Reverse Hybrid Entity created under UAE law.
This is particularly relevant for multinational groups with several UAE subsidiaries, joint ventures or other entities falling within the Pillar Two rules.
Can one UAE entity file the return for other group entities?
Yes.
Ministerial Decision No. 133 of 2026 allows the Pillar Two Information Return to be filed either directly by the relevant Constituent Entity, Joint Venture or JV Subsidiary, or by a Designated Local Entity on its behalf.
This provides multinational groups with an option to centralise the filing process through an appropriate UAE entity rather than requiring every relevant entity to separately manage the filing.
However, the group should first determine which UAE entities fall within the filing requirement and whether the relevant conditions for using a Designated Local Entity are satisfied.
What information must be included in the Pillar Two Information Return?
The reporting requirements are linked to Article 15 of the Annexure to Cabinet Decision No. 142 of 2024.
The Information Return is intended to provide information relevant to the application of the Pillar Two rules, including information concerning the relevant entities, the group's structure and information required for the determination of the effective tax rate and any applicable Top-up Tax.
The UAE legislation also provides for information relating to elections and other information required under the applicable Pillar Two implementation framework.
The Ministry of Finance has additionally issued Ministerial Decision No. 96 of 2026 concerning the Commentary and Agreed Administrative Guidance for the purposes of Cabinet Decision No. 142 of 2024. This decision is listed among the UAE's current 2026 tax legislation.
When does Ministerial Decision No. 133 of 2026 apply?
The decision applies to Fiscal Years starting on or after 1 January 2025.
This means that multinational groups should not treat the new decision as a requirement beginning only with future financial years. Its application reaches back to fiscal years commencing from 1 January 2025, subject to the specific rules applicable to the group and its entities.
Under Article 15.4 of Cabinet Decision No. 142 of 2024, the Pillar Two Information Return is generally required no later than 15 months after the last day of the Reporting Fiscal Year, subject to the applicable provisions of the decision.
For a group whose Reporting Fiscal Year ended 31 December 2025, this 15-month period would generally lead to a filing date of 31 March 2027.
Does this apply to every company in the UAE?
No.
The UAE Pillar Two regime is designed for large multinational enterprise groups, rather than ordinary UAE companies.
The €750 million global revenue threshold is a key starting point for determining whether an MNE Group falls within the UAE Top-up Tax rules. The threshold is based on the group's consolidated global revenue and is tested over the relevant preceding financial years.
Therefore, a UAE company should not determine its position simply by looking at its own UAE turnover.
A UAE subsidiary may have relatively modest local revenue while still being part of an MNE Group that falls within the Pillar Two rules.
What is the UAE Domestic Minimum Top-up Tax?
The UAE Domestic Minimum Top-up Tax (DMTT) is the UAE's domestic implementation of the Pillar Two minimum taxation rules.
It applies to Constituent Entities of qualifying MNE Groups where the relevant global revenue threshold is met. The DMTT has applied to financial years starting on or after 1 January 2025.
The UAE Ministry of Finance has also confirmed that the UAE has not implemented the Income Inclusion Rule (IIR) at this stage and continues to monitor international developments concerning its implementation.
This distinction is important because the UAE's Pillar Two regime contains several specific rules, exclusions and mechanisms that need to be considered when determining the group's UAE position.
What should multinational businesses in the UAE do now?
Businesses that may fall within the Pillar Two regime should first establish whether their group meets the €750 million global revenue threshold and identify all UAE entities that may qualify as Constituent Entities, Joint Ventures or JV Subsidiaries.
They should then review:
The group's consolidated financial statements and relevant preceding financial years;
The UAE entities forming part of the MNE Group;
Whether any entity qualifies as an Investment Entity;
Whether a Designated Local Entity should be used for filing;
The group's Pillar Two calculations and supporting information;
The applicable Information Return requirements under Article 15 of Cabinet Decision No. 142 of 2024; and
The applicable filing and notification requirements with the FTA.
The UAE Ministry of Finance's financial legislation portal currently lists Ministerial Decision No. 133 of 2026 alongside Ministerial Decision No. 96 of 2026 and other current Pillar Two legislation.
What does this mean for UAE subsidiaries of multinational groups?
For UAE subsidiaries of large multinational groups, the latest decision makes one point particularly clear: being a UAE subsidiary does not by itself determine the filing obligation. The entity's position within the wider MNE Group and the applicable Pillar Two rules must be assessed.
Companies should therefore look beyond their individual UAE accounts and consider their wider group structure, consolidated revenue and Pillar Two classification.
With the UAE DMTT already applicable from 1 January 2025 and Ministerial Decision No. 133 of 2026 now specifying the entities responsible for the Information Return, multinational groups should ensure that their UAE entities are properly identified and that the necessary reporting processes are in place.
Conclusion
The issuance of Ministerial Decision No. 133 of 2026 is another significant step in the UAE's implementation of the Pillar Two global minimum tax regime.
The decision clarifies which UAE entities are required to file the Pillar Two Information Return, allows certain filings to be made through a Designated Local Entity, and applies to Fiscal Years starting on or after 1 January 2025.
For multinational groups operating through UAE subsidiaries, joint ventures or other qualifying entities, reviewing the group's structure and Pillar Two reporting obligations should now form part of its UAE tax compliance process.
