UAE Pillar Two: New Filing Rules Explained

The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, providing long-awaited clarity on which entities must file the Pillar Two Information Return with the Federal Tax Authority (FTA). This decision marks a significant step in the UAE's continued implementation of the OECD/G20 Inclusive Framework's international tax reforms and reinforces the country's commitment to global tax transparency.

The Pillar Two Information Return—the UAE's implementation of the GloBE Information Return (GIR)—is the informational filing through which multinational enterprise (MNE) groups report their compliance with the 15% global minimum tax regime. This filing obligation operates under the framework established by Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.

Under Ministerial Decision No. 133/2026, the following entities located in the UAE are required to file the Pillar Two Information Return:

• Each Constituent Entity located in the UAE, excluding Investment Entities
• Each Joint Venture and JV Subsidiary located in the UAE
• Each Stateless Constituent Entity that is a Reverse Hybrid Entity created under UAE law

This means that even where the controlling parent company sits outside the UAE, the filing obligation can fall on the UAE-located entity. Companies should not assume that the foreign parent will handle this obligation.

The Decision permits the Pillar Two Information Return to be filed either directly by the Constituent Entity, Joint Venture, or JV Subsidiary; or by a Designated Local Entity acting on behalf of the relevant entity. This flexibility allows MNE groups to coordinate their UAE Pillar Two compliance and reporting obligations more efficiently.

Importantly, a UAE entity may be exempt from filing directly with the FTA where the required return has already been filed by another group entity in a qualifying jurisdiction. This applies where the return has been filed by either the Ultimate Parent Entity (UPE) located in a jurisdiction with a Qualifying Competent Authority Agreement (QCAA) in effect with the UAE; or the Designated Filing Entity (DFE) located in a jurisdiction with a QCAA in effect with the UAE.

However, even where this exemption applies, notification obligations remain. The UAE entity or Designated Local Entity must notify the FTA of the identity and location of the entity responsible for filing the return.

The Pillar Two rules apply to MNE groups with consolidated global revenue of at least EUR 750 million in at least two of the four preceding fiscal years. Critically, this threshold is assessed at the group level, not at the level of individual UAE entities. As a result, a relatively small UAE subsidiary could fall under the regime if it belongs to a sufficiently large multinational group.

In-scope companies should be aware of the following key dates:

• Registration deadline: Companies covered by the regime must register by 30 November 2026 
• First return and payment: Due by 30 June 2027 
• General filing deadline: Returns must be filed within 15 months of the end of the reporting fiscal year, extended to 18 months for the first transitional year 
• Effective Date - Ministerial Decision No. 133/2026 applies to fiscal years beginning on or after 1 January 2025. For groups on a calendar year, the first affected period is the one ending 31 December 2025.

The filing obligation may not be automatic, and the exemption from local filing is not automatic either. Companies should retrieve two key data points from their parent's consolidated accounts: consolidated revenues for the last four financial years to establish whether the group exceeds the EUR 750 million threshold, and the closing date of the first in-scope financial year.

The compliance cycle for the first fiscal year has already begun. Entity mapping, governance choices, and data readiness are current-year work—not tasks to defer until the deadline.

This article is for informational purposes only and does not constitute legal or tax advice. Please consult with a qualified professional for guidance specific to your circumstances.