If your group falls within the scope of the UAE’s Top-Up Tax regime, working out exactly who is responsible for filing the Pillar Two Information Return in the UAE has just become considerably clearer. On 3 August 2026, the Ministry of Finance issued Ministerial Decision No. 133 of 2026, setting out precisely which entities must file this return with the Federal Tax Authority (FTA) for fiscal years starting on or after 1 January 2025.
For multinational enterprises (MNEs) with UAE operations, this is not a compliance detail to leave until the deadline is close. Getting the filing entity, the exemption route, and the notification obligations wrong can expose the group to penalties under the UAE’s Tax Procedures framework. This guide breaks down what the new decision says, who it affects, and what UAE entities should do next.
What Is the Pillar Two Information Return?
The Pillar Two Information Return is the UAE’s domestic filing mechanism that sits alongside the OECD/G20 Global Anti-Base Erosion (GloBE) Information Return. It is part of the reporting infrastructure introduced under Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises, the legislation that brought the UAE’s Domestic Minimum Top-Up Tax (DMTT) into force.
- The DMTT applies to in-scope MNE groups with consolidated global revenue of at least EUR 750 million in at least two of the four preceding fiscal years.
- It ensures that UAE constituent entities of these groups pay an effective tax rate of at least 15%, in line with the OECD’s GloBE Model Rules.
- The Information Return gives the FTA the data needed to verify that the top-up tax has been calculated and applied correctly.
Ministerial Decision No. 133 of 2026 does not introduce a new tax or change the 15% rate. It clarifies the filing responsibility side of an already-legislated regime.
Who Must File the Pillar Two Information Return in the UAE?
Under Article 2 of Ministerial Decision No. 133 of 2026, three categories of entities located in the UAE are required to file a Pillar Two Information Return with the FTA, conforming to the requirements of Article 15 of the Annexure to Cabinet Decision No. 142 of 2024:
- Every Constituent Entity located in the UAE, excluding any Investment Entity
- Every Joint Venture and JV Subsidiary located in the UAE
- Every Stateless Constituent Entity that is a Reverse Hybrid Entity created under UAE law
Each of these entities carries the filing obligation individually, unless one of the exemptions below applies.
Who Can File on Behalf of the Group?
The decision gives groups flexibility over how the return is submitted. A Pillar Two Information Return may be filed by:
- The Constituent Entity, Joint Venture or JV Subsidiary itself, or
- A Designated Local Entity, filing centrally on behalf of one or more in-scope entities in the UAE
This allows a group with several UAE entities to consolidate reporting through a single Designated Local Entity rather than each entity filing separately, reducing duplication of effort across the group’s UAE structure.
When Is a UAE Entity Exempt From Filing?
A Constituent Entity, Joint Venture or JV Subsidiary is not required to file its own Pillar Two Information Return with the FTA where an equivalent return, meeting Article 15 requirements, has already been filed by either:
- The Ultimate Parent Entity, located in a jurisdiction with a Qualifying Competent Authority Agreement (QCAA) in effect with the UAE for the relevant Reporting Fiscal Year, or
- The Designated Filing Entity, located in a jurisdiction with a QCAA in effect with the UAE for the relevant Reporting Fiscal Year
This mirrors the internationally agreed approach to GloBE reporting, where a single, centrally filed return can be exchanged between tax authorities under an information exchange agreement, avoiding duplicate filings across multiple jurisdictions.
The Notification Requirement Groups Often Miss
Relying on the exemption does not remove every obligation. Where the exemption applies, the UAE entity (or the Designated Local Entity acting on its behalf) must still notify the FTA of:
- The identity of the entity that is filing the Pillar Two Information Return, and
- The location (jurisdiction) of that filing entity
This notification step is a separate compliance action from the return itself. Groups that assume the exemption is automatic and skip the notification risk falling out of compliance even though no tax liability arises from the omission itself.
Effective Date and Application
- Ministerial Decision No. 133 of 2026 applies to Fiscal Years starting on or after 1 January 2025.
- The Decision is published and effective from its date of issuance.
- It was signed by Mohamed bin Hadi Al Hussaini, Minister of State for Financial Affairs, and corresponds to 20 Safar 1448H (3 August 2026).
Because the Decision applies to fiscal years already open or closed as of 1 January 2025, groups should review their UAE filing position now rather than waiting for a formal FTA reminder.
What UAE Entities Should Do Now
- Map every UAE entity in the group against the three filing categories above
- Confirm whether an Investment Entity exclusion genuinely applies, rather than assuming it by default
- Identify whether the group’s Ultimate Parent Entity or Designated Filing Entity is located in a QCAA jurisdiction with the UAE
- Decide whether to file individually per entity or centralise through a Designated Local Entity
- Prepare and diarise the FTA notification where the exemption route is used
- Cross-check this filing obligation against related DMTT registration and deregistration deadlines already in force
Frequently Asked Questions
Does Ministerial Decision No. 133 of 2026 create a new tax?
No. It does not change the DMTT rate or introduce a new charge. It clarifies which UAE entities carry the obligation to file the Pillar Two Information Return, and how that obligation can be satisfied or exempted.
Which entities are excluded from filing?
Investment Entities located in the UAE are excluded from the Constituent Entity filing category under Article 2(1)(a) of the Decision.
Can one UAE entity file for the whole group?
Yes. A Designated Local Entity may file the Pillar Two Information Return on behalf of the Constituent Entity, Joint Venture or JV Subsidiary.
Get a Pillar Two Filing Position Review From Tax Gian
Working out whether your UAE entity must file directly, qualifies for the QCAA-based exemption, or should route reporting through a Designated Local Entity is a structural decision, not a form-filling exercise. Getting it wrong on either side carries compliance risk.
Tax Gian’s tax advisors work with UAE constituent entities, joint ventures and multinational groups to confirm Pillar Two and DMTT filing positions, prepare Information Return submissions, and manage the FTA notification process where an exemption applies.
Contact Tax Gian today to book a Pillar Two Information Return filing review for your UAE entity and stay ahead of the Federal Tax Authority’s reporting requirements.
