The Ministry of Finance has issued Ministerial Decision No. 133/2026, setting out the entities required to file Pillar Two information returns under Cabinet Decision No. 142/2024 on the Imposition of Top-up Tax on Multinational Enterprise.
The decision forms part of the UAE’s continued implementation of the OECD/G20 Inclusive Framework’s Pillar Two rules, reinforcing its commitment to international tax transparency and providing greater certainty for multinational enterprises regarding their reporting obligations.
The regulation specifies that all member entities located in the UAE — excluding investment entities — as well as joint ventures, subsidiaries of joint ventures, and reverse hybrid entities established under UAE law, must submit Pillar Two information returns to the Federal Tax Authority. Returns may be filed directly by the entity or through a designated local entity acting on its behalf.
The decision applies to financial years beginning on or after 1 January 2025, ensuring consistent application of the global minimum tax rules designed to combat base erosion.
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