The UAE Ministry of Finance issued Ministerial Decision No. 133 of 2026 on 25 August 2026, setting out which multinational entities operating in the UAE must file the Pillar Two Information Return with the Federal Tax Authority (FTA). The decision builds on Cabinet Decision No. 142 of 2024, which established the country's Top-up Tax framework aligned with the OECD/G20 GloBE Rules, and applies to fiscal years starting on or after 1 January 2025.
What happened
According to the official MoF press release, Ministerial Decision No. 133 of 2026 sets out the filing obligations for the Pillar Two Information Return for multinational enterprises operating in the UAE under the Top-up Tax regime. The document extends Cabinet Decision No. 142 of 2024 'On the Imposition of Top-Up Tax on Multinational Enterprises' and slots the return into the broader architecture of the Pillar Two Global Anti-Base Erosion (GloBE) Rules — the model rules of the OECD/G20 Inclusive Framework.
In the ministry's own words, the decision 'reaffirms the country's commitment to enhancing international tax transparency, while providing greater tax certainty and clarity for multinational enterprises regarding their reporting obligations.' That is the core message of the document: not a new headline tax, but a standardised answer to the question of who reports what — and how.
Who must file the Pillar Two Information Return
Decision 133/2026 lists three categories of entities that must file a return with the FTA:
- each Constituent Entity located in the UAE, excluding any Investment Entity;
- each Joint Venture and its JV Subsidiary located in the UAE;
- each Stateless Constituent Entity that is a Reverse Hybrid Entity created in accordance with UAE law.
A Constituent Entity, in Pillar Two terms, is a legal entity or permanent establishment consolidated into the accounts of a multinational enterprise group subject to GloBE. A Reverse Hybrid Entity is a structure whose tax transparency in the jurisdiction of formation and its treatment in the jurisdiction of the investor diverge; for GloBE purposes, such entities require distinct treatment. Excluding Investment Entities from the filing scope is a standard element of the GloBE architecture: investment funds and related structures have their own dedicated regime inside Pillar Two.
How to file: direct or via a Designated Local Entity
The decision expressly provides two filing models:
- the return is filed directly by the Constituent Entity, Joint Venture or JV Subsidiary — each obligated entity on its own;
- the return is filed by a Designated Local Entity — a single appointed entity that reports on behalf of the other obligated entities of the group in the UAE.
The second model tends to be the more practical option for groups with several UAE entities: one point of contact with the FTA reduces the risk of divergent data and eases the workload of the group's finance teams. The formal appointment mechanics and the filing workflow itself will be spelled out through FTA regulations; the details should be tracked as guidance is published.
How this slots into Top-up Tax and GloBE
Ministerial Decision No. 133 of 2026 does not move the headline rate and does not redefine who is inside the Top-up Tax perimeter itself — those rules sit in the anchor act, Cabinet Decision No. 142 of 2024. Decision 133/2026 answers only the 'who reports and how' question to the FTA.
The broader Pillar Two logic (OECD/G20 Inclusive Framework model rules, December 2021): for large multinational groups — the GloBE standard threshold is consolidated revenue of €750 million in two of the four preceding fiscal years — a minimum effective corporate tax rate of 15% is set for every jurisdiction of operation. If the effective rate in a given country falls below 15%, the difference is picked up through a Top-up Tax mechanism — typically in the parent's jurisdiction (Income Inclusion Rule) or, as a backstop, at the level of the Constituent Entity (Undertaxed Payments Rule). The UAE has adopted its own Domestic Minimum Top-up Tax under Cabinet Decision 142/2024, allowing the country to collect the top-up locally rather than surrendering it to other jurisdictions.
The information layer — precisely the Pillar Two Information Return — is the technical core of the whole system: jurisdictional effective tax rate, Covered Taxes, GloBE Income, safe harbours, adjustments. Without this reporting, the Top-up Tax mechanics cannot function. That is exactly what Decision 133/2026 standardises.
What UAE-based businesses should do now
For multinational groups with UAE entities and their tax teams, four steps make sense in the coming months.
- Check whether you fall inside the Pillar Two perimeter. The GloBE standard threshold is €750 million of consolidated group revenue in two of the four preceding fiscal years. If the group is below the threshold, Pillar Two does not apply, no Return obligation arises, and the standard UAE 9% corporate tax above AED 375,000 continues to apply (see the base explainer 'UAE corporate tax 9% above AED 375,000').
- Map each UAE entity of the group. Which are Constituent Entities, which are Investment Entities (out of scope), which are Joint Ventures or JV Subsidiaries. Separately, check whether the group has any Reverse Hybrid Entities created under UAE law — they are also in scope.
- Take a call on the Designated Local Entity. If there are several UAE entities of the group, appointing a single Designated Local Entity is likely more practical — a single point of contact with the FTA and unified data quality control.
- Get the GloBE data ready. Jurisdictional effective tax rate, Covered Taxes, GloBE Income, applicable safe harbours (including the Transitional CbCR Safe Harbour) — these all need to be reconciliation-ready by the time the Return is filed. It is worth walking through the checkpoints with the group and its tax advisers now — the UAE corporate tax base and the connected obligations are covered in 'who pays the UAE 9% corporate tax'.
Primary source: Ministry of Finance UAE press release, 25 August 2026. Corroboration and business commentary: Gulf News, Justin Varghese. Technical framework: GloBE Model Rules of the OECD/G20 Inclusive Framework, December 2021.
