Dubai, UAE: The UAE has issued new rules clarifying which multinational enterprise (MNE) entities must file the Pillar Two Information Return with the Federal Tax Authority (FTA). The Ministry of Finance issued Ministerial Decision No. 133 of 2026 on 25 August 2026, adding more clarity to the reporting duties under the UAE Top-Up Tax framework.
The decision applies to fiscal years starting on or after 1 January 2025. It is relevant to MNE groups within the UAE Top-Up Tax framework, which covers groups with annual global revenue of €750 million or more in at least two of the four financial years before the relevant financial year.
Who Must File the Pillar Two Information Return?
Under the new decision, the filing requirement can apply to several types of UAE entities.
These include each UAE Constituent Entity, except an Investment Entity, that is part of an in-scope MNE group. The requirement also covers relevant Joint Ventures and JV Subsidiaries located in the UAE.
In addition, certain Stateless Constituent Entities that are Reverse Hybrid Entities created under UAE law are included.
This means MNE groups should not look only at their parent company when reviewing their reporting duties. They need to identify the UAE entities that fall within the scope of the Pillar Two rules and review their tax compliance obligations.
MNEs Can Use Different Filing Arrangements
The new decision also provides flexibility in how the Pillar Two Information Return can be submitted.
An in-scope entity can file the return directly. Alternatively, a Designated Local Entity can submit the return on behalf of the relevant UAE group entities where the applicable requirements are met.
This is particularly relevant for MNE groups with several UAE entities because the group can review its structure and determine the appropriate local filing arrangement.
Latest FTA Guidance Adds More Clarity
The new Ministry of Finance decision was followed by additional FTA guidance on 26 August 2026. The FTA published TTGREG1, Scope and Registration, and TTGEIE1, Excluded Entities and Investment Entities, as new Top-Up Tax guides.
These publications give MNEs further guidance when assessing whether their UAE entities fall within the Top-Up Tax framework and how excluded entities should be considered.
This is an important point for businesses because being treated as an exempt person under the UAE Corporate Tax framework does not, by itself, mean that an entity should assume it is outside every Pillar Two requirement. The relevant status must be reviewed under the applicable Top-Up Tax rules. Businesses may need Corporate Tax advisory support when reviewing how their tax position interacts with wider UAE requirements.
What Happens If the Requirements Are Ignored?
MNEs that overlook their reporting duties may face administrative consequences under the applicable tax legislation. More importantly, failing to identify the correct UAE filing entity or reporting arrangement can create compliance problems for the group.
The new rules therefore make it important for MNEs to review their UAE structure rather than wait until a filing deadline approaches.
What MNEs Should Do Now
Businesses within the Pillar Two scope should first confirm whether their group meets the €750 million global revenue test. They should then identify all UAE Constituent Entities, relevant Joint Ventures and JV Subsidiaries, and any other entities that may fall within the rules.
MNEs should also determine whether they will file directly or use a Designated Local Entity, review the latest FTA guidance and prepare the financial statements and reporting information needed for their reporting obligations.
For businesses operating across several jurisdictions, this review can involve complex tax and compliance considerations. Dubai Business & Tax Advisors (DBTA) can support businesses with tax advisory services, tax compliance services, and audit and assurance services, helping MNEs assess their UAE position and understand the reporting requirements that apply to their structure.
With Ministerial Decision No. 133 of 2026 now providing clearer filing rules, UAE-based MNEs should treat Pillar Two reporting as an active compliance matter and review their obligations under the updated framework.
