UAE Clarifies Pillar Two Tax Reporting for Multinational Groups

UAE, 16 September, 2026: The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, clarifying which entities within multinational groups must file a Pillar Two Information Return with the Federal Tax Authority.

The rules apply to fiscal years beginning on or after 1 January 2025 and form part of the UAE’s implementation of the OECD/G20 Pillar Two Global Anti-Base Erosion (GloBE) Rules.

Who Must File?

The reporting requirement generally covers:

• UAE-based Constituent Entities of multinational groups, excluding Investment Entities.
• UAE-based Joint Ventures and Joint Venture Subsidiaries.
• Certain Stateless Constituent Entities that are Reverse Hybrid Entities established under UAE law.

Entities may file the return directly or through a Designated Local Entity in the UAE.

The Ministry clarified that the decision does not introduce a new Top-up Tax. Instead, it provides greater clarity on reporting responsibilities under the existing UAE Pillar Two framework established by Cabinet Decision No. 142 of 2024.

The new guidance is intended to support compliance, improve tax transparency and provide greater certainty for multinational enterprises operating in the UAE.