Pillar Two in the UAE: Who Must File the Information Return
The Ministry of Finance issued Ministerial Decision No. 133 of 2026 on 25 August 2026. It sets out which entities must file the Pillar Two Information Return with the Federal Tax Authority under the UAE's Domestic Minimum Top-up Tax. The FTA also published new guides on scope, registration and excluded entities.
The Top-up Tax applies to multinational groups with consolidated revenue of EUR 750 million or more. The Decision covers financial years starting on or after 1 January 2025. It does not create a new tax; it clarifies reporting.
Who must file
- Each UAE constituent entity of an in-scope group, other than investment entities
- UAE joint ventures and their subsidiaries
- Certain reverse hybrid entities
A Designated Local Entity can file on behalf of the group's UAE entities. No UAE return is needed where the parent files in a country with a qualifying exchange agreement with the UAE, but the FTA must still be notified.
Key dates
- Registration: within 7 months of the end of the first in-scope financial year, or by 30 November 2026 for financial years that ended before 30 April 2026.
- Transitional relief: for early years, no penalties apply where the FTA accepts the group took reasonable measures to comply.
Official source: UAE Ministry of Finance - Tax Legislation (Ministerial Decision No. 133 of 2026) | Federal Tax Authority - Legislation and Guides