If your business forms part of a multinational group operating in the UAE, a new Ministerial Decision issued in August 2026 has answered a question many finance and tax teams have been asking since the UAE's global minimum tax rules came into force: who, exactly, is responsible for filing?

The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, setting out which UAE entities within multinational enterprise groups must submit a Pillar Two Information Return to the Federal Tax Authority (FTA). The decision does not introduce a new tax. Instead, it clarifies the filing obligations under the UAE's existing Top-up Tax regime, giving in-scope multinational enterprises greater clarity around their reporting responsibilities.

Here's what the decision changes, who it applies to, and what businesses should be doing about it now.

What Is the Pillar Two Information Return?

The Pillar Two Information Return is the UAE reporting mechanism supporting the Global Anti-Base Erosion (GloBE) Rules, commonly known as Pillar Two, developed under the OECD/G20 Inclusive Framework. These rules are designed to establish a global minimum tax framework for large multinational enterprise groups.

The UAE's domestic Top-up Tax regime was established through Cabinet Decision No. 142 of 2024, which introduced the UAE's Domestic Minimum Top-up Tax (DMTT) for qualifying multinational enterprise groups. The regime applies to MNE groups meeting the relevant €750 million global revenue threshold. Ministerial Decision No. 133 of 2026 builds this framework by clarifying which UAE entities are required to file the Pillar Two Information Return.

The UAE has also adopted OECD guidance and commentary relating to the GloBE Rules through Ministerial Decision No. 88 of 2025, with further guidance issued subsequently.

Who Must File the Pillar Two Information Return?

Under Ministerial Decision No. 133 of 2026, the following UAE entities are required to file a Pillar Two Information Return with the FTA:

• Each Constituent Entity in the UAE, except for an Investment Entity.
• Each Joint Venture and JV Subsidiary located in the UAE.
• Each Stateless Constituent Entity that is a Reverse Hybrid Entity created in accordance with UAE law.

The inclusion of joint ventures is worth noting. Pillar Two reporting is not limited to wholly owned companies within a multinational group's structure. UAE-based Joint Ventures and JV Subsidiaries are specifically included within the reporting requirements under the new decision.

How Can the Return Be Filed?

The Ministry has also clarified the mechanics of submission.

A Constituent Entity, Joint Venture or JV Subsidiary can file its own Pillar Two Information Return directly with the FTA.

Alternatively, a group may use a Designated Local Entity to file the return on behalf of the relevant covered UAE entities. This can allow multinational groups with several UAE entities to centralise their reporting rather than requiring every entity to submit separately.

For groups with multiple UAE entities, this makes it important to determine early which entity will take responsibility for the filing and how the required information will be collected across the group.

Which Fiscal Years Are Covered?

Ministerial Decision No. 133 of 2026 applies to Fiscal Years beginning on or after 1 January 2025. This is consistent with the UAE's Top-up Tax framework under Cabinet Decision No. 142 of 2024, which also applies to Fiscal Years beginning on or after 1 January 2025.

This means that many multinational groups with UAE operations are already within the relevant reporting period, even though Ministerial Decision No. 133 of 2026 was issued in August 2026.

Why This Decision Matters for Multinational Businesses

For finance and tax teams managing UAE entities within a larger multinational group, this decision provides greater clarity around local filing responsibility.

That matters for a few practical reasons:

Compliance planning — Groups can now identify which UAE entities have a Pillar Two Information Return filing obligation instead of making assumptions across the entire structure.

Centralised reporting — The Designated Local Entity option provides a mechanism for groups with multiple UAE entities to centralise their UAE reporting.

Joint venture exposure — Businesses with UAE-based Joint Ventures and JV Subsidiaries now have explicit confirmation that these structures can fall within the Pillar Two reporting perimeter.

Data and systems readiness — Groups will need to coordinate information between their UAE entities and the wider group reporting process to ensure the information required for the Pillar Two return is available and consistent.

Key Takeaways

What Businesses Should Do Now

If your company sits within a multinational group with a UAE presence, the next step is to review your group structure and confirm whether any UAE entities fall within the filing categories under Ministerial Decision No. 133 of 2026.

Businesses should consider:

• Identify all UAE Constituent Entities, Joint Ventures, and JV Subsidiaries within the group.
• Check whether any Investment Entity or other Excluded entity applies.
• Determining whether a Designated Local Entity will be used for UAE filing purposes.
• Coordinating with the group's global tax team to ensure the required Pillar Two information is available.
• Reviewing the latest UAE Ministry of Finance and Federal Tax Authority guidance before preparing the return.

The UAE's Pillar Two compliance framework continues to develop, with the Ministry of Finance and FTA issuing additional legislation, guidance and technical material. The FTA's current Corporate Tax guidance section includes dedicated Top-up Tax guidance, including material on scope and registration and excluded entities and Investment Entities.

For multinational groups, getting the reporting structure, responsibilities and supporting data organised early can help reduce the risk of last-minute compliance issues.

Need Help Understanding UAE Pillar Two Requirements?

If your business is part of a multinational group with operations in the UAE, understanding whether your UAE entities have a Pillar Two Information Return obligation is an important part of your tax compliance planning.

Our corporate tax advisory team can help you review your UAE structure, understand the relevant reporting requirements, and identify the appropriate compliance steps under the UAE's current Top-up Tax framework.

Key UAE Laws, Decisions and Authorities

1. Cabinet Decision No. 142 of 2024 — Imposition of Top-up Tax on Multinational Enterprises.
2. Ministerial Decision No. 88 of 2025 — Adoption of OECD Commentary and Administrative Guidance on the GloBE Rules.
3. Ministerial Decision No. 133 of 2026 — Entities Required to File the Pillar Two Information Return.
4. Federal Tax Authority (FTA) — Current Corporate Tax and Top-up Tax guidance.
5. OECD/G20 Inclusive Framework — Global Anti-Base Erosion (GloBE) / Pillar Two framework.

Disclaimer: This article is for general informational purposes only and reflects the UAE tax framework and guidance available as of September 2026. Pillar Two and UAE Top-up Tax compliance can depend on the specific structure and circumstances of an MNE group. Businesses should obtain professional tax advice and refer to the latest legislation and guidance issued by the UAE Ministry of Finance and Federal Tax Authority before taking action.