UAE Clarifies Pillar Two Information Return Filing Rules for Multinationals

The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, clarifying which entities are required to file the Pillar Two Information Return with the Federal Tax Authority. The Decision forms part of the UAE's implementation of the OECD/G20 Pillar Two Global Anti-Base Erosion, or GloBE, framework and applies in connection with the UAE's Domestic Minimum Top-up Tax for multinational enterprises. The rules apply to fiscal years beginning on or after 1 January 2025.

The UAE Top-up Tax regime does not apply to ordinary SMEs or most standalone UAE businesses.

Cabinet Decision No. 142 of 2024 applies to multinational enterprise groups with annual consolidated global revenue of at least EUR 750 million in at least two of the four fiscal years immediately preceding the relevant fiscal year.

A multinational group generally involves entities or permanent establishments operating across more than one jurisdiction. The August Decision therefore concerns a relatively specific category of large international corporate groups rather than introducing a new general filing obligation across the UAE business community.

Ministerial Decision No. 133 identifies three principal categories required to submit a Pillar Two Information Return to the Federal Tax Authority:

• each UAE-located Constituent Entity, 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.

The purpose is to ensure that the FTA receives the information required to administer the UAE's Top-up Tax framework consistently with the international Pillar Two rules.

The Decision provides an important administrative option for multinational groups. The required Pillar Two Information Return does not necessarily have to be filed separately by every entity. A Constituent Entity, Joint Venture or JV Subsidiary may file the return itself, or a Designated Local Entity may submit the return on its behalf.

This allows multinational groups with several UAE entities to centralise aspects of their Pillar Two reporting structure where the requirements are satisfied. However, groups should formally determine which entity will assume the filing responsibility rather than assuming that another group company is automatically responsible.

Cabinet Decision No. 142 of 2024 sets out the underlying information expected in the Pillar Two Information Return. This includes details concerning:

• the identities and tax status of Constituent Entities;

• the multinational group's corporate structure;

• jurisdictional effective tax rates;

• Top-up Tax calculations;

• Joint Venture calculations;

• relevant Pillar Two elections; and

• other information required under the international Pillar Two implementation framework.

The return follows the standard framework developed by the OECD/G20 Inclusive Framework.

For affected groups, this means Pillar Two compliance requires significantly more than simply calculating UAE Corporate Tax at the standard domestic rate.

Under Cabinet Decision No. 142 of 2024, the Pillar Two Information Return must generally be filed with the Federal Tax Authority no later than 15 months after the end of the relevant Reporting Fiscal Year.

Businesses should distinguish this from the separate Top-up Tax Return. The Top-up Tax Return also generally has a 15-month filing deadline, but the Cabinet Decision allows 18 months after the end of the Reporting Fiscal Year where that year is the first Transition Year of any Constituent Entity in the MNE Group. The Pillar Two Information Return and Top-up Tax Return are therefore related parts of the same regime, but they are distinct reporting obligations.

The filing clarification does not introduce the Top-up Tax itself. The UAE previously introduced its Domestic Minimum Top-up Tax under Cabinet Decision No. 142 of 2024, applicable to in-scope multinational groups for fiscal years beginning on or after 1 January 2025.

The UAE framework is aligned with the OECD's Pillar Two rules and is designed around a 15% global minimum effective tax framework for qualifying multinational groups. The Ministry of Finance has subsequently issued further decisions and guidance to establish how the regime operates in practice.

On 26 August, the FTA also published dedicated Top-up Tax guides covering Scope and Registration and Excluded Entities and Investment Entities, providing additional technical guidance for affected multinational groups.

NUR Advisory Note

The new Decision is relevant primarily to large multinational groups with UAE operations, rather than the general UAE corporate sector.

Groups that may fall within the EUR 750 million revenue threshold should not assess Pillar Two obligations solely at the level of an individual UAE company.

The analysis should be conducted across the multinational group and should identify:

• whether the global revenue threshold is met;

• which UAE companies qualify as Constituent Entities;

• whether any entities qualify for an exclusion;

• whether UAE Joint Ventures or JV Subsidiaries are within scope;

• which entity will file the Pillar Two Information Return;

• whether a Designated Local Entity will be used;

• the applicable reporting deadlines; and

• whether systems and group reporting processes can produce the data required under the GloBE framework.

International groups entering the UAE should also consider Pillar Two implications when designing their UAE structure. The standard UAE Corporate Tax position of an individual entity may not, by itself, determine the group's overall tax position under the global minimum tax framework.

For smaller UAE companies and groups outside the Pillar Two revenue threshold, Ministerial Decision No. 133 does not create a new Pillar Two Information Return requirement.