Published: 2026-08-26
The UAE Ministry of Finance issued Ministerial Decision No. 133 of 2026 on 2026-08-26, defining which members of a multinational group must file the Pillar Two Information Return with the Federal Tax Authority (FTA). Three categories are covered: every constituent entity located in the UAE, except investment entities; every joint venture and joint venture subsidiary located in the UAE; and every stateless constituent entity that is a reverse hybrid entity created under UAE law. Each of them can file directly, or a designated local entity can submit the return on their behalf, which allows a group to centralise the filing for all of its UAE members in one company. The decision applies to fiscal years starting on or after 2025-01-01, the same start date as the UAE Top-up Tax introduced by Cabinet Decision No. 142 of 2024. It does not create a new tax: the 15% domestic minimum top-up tax for groups with consolidated revenue of EUR 750 million or more is already in force, and the new decision closes the practical question of who is responsible for the reporting that comes with it.
What Ministerial Decision No. 133 of 2026 requires
The decision is short and operational. It answers one question: within a multinational group that falls under the UAE Top-up Tax, which UAE entities owe the FTA a Pillar Two Information Return. The answer, per the Ministry of Finance announcement, is set out below.
| Entity located in the UAE | Filing obligation | How it can file |
|---|---|---|
| Constituent entity of an in-scope group | Must file | Directly, or via a designated local entity |
| Investment entity | Excluded from the filing requirement | Not applicable |
| Joint venture or joint venture subsidiary | Must file | Directly, or via a designated local entity |
| Stateless constituent entity that is a reverse hybrid entity created under UAE law | Must file | Directly, or via a designated local entity |
The designated local entity is the key practical feature. A group with several UAE companies, a joint venture and a branch does not need each of them to prepare and submit the same group-level data separately. One UAE member can be designated to file on behalf of the others, and the FTA receives a single return covering all of them. Groups that prefer entity-by-entity filing keep that option.
The Ministry of Finance described the decision as support for the consistent implementation of the OECD/G20 Inclusive Framework’s Global Anti-Base Erosion (GloBE) Rules and as part of the UAE’s effort to strengthen international tax transparency and give multinational enterprises certainty over their reporting obligations. The announcement did not include a separate filing deadline for the information return, penalty provisions or named officials, so those elements are governed by the existing Top-up Tax framework and future FTA guidance.
Where this sits in the UAE Pillar Two framework
The UAE joined the OECD global minimum tax through Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises, announced in December 2024. It applies a domestic minimum top-up tax so that in-scope groups pay an effective rate of at least 15% on their UAE profits, for fiscal years starting on or after 2025-01-01. A group is in scope if its consolidated revenue was EUR 750 million or more in at least two of the four fiscal years preceding the tested year. The top-up tax return and payment fall due within 15 months after the end of the fiscal year, extended to 18 months for the transitional first year, which means a calendar-year group’s first filing for 2025 is due by 2027-06-30.
Two further pieces were added in 2026. Ministerial Decision No. 96 of 2026, issued on 2026-06-22, adopted the OECD’s 2026 Consolidated Commentary and Administrative Guidance for the UAE regime and attached the OECD GloBE Information Return template (January 2025 version) as an annex, replacing Ministerial Decision No. 88 of 2025. The FTA has also opened Top-up Tax registration in the EmaraTax portal, with a route for a domestic designated filing entity to register on behalf of the group’s UAE members. Ministerial Decision No. 133 of 2026 completes the picture on the reporting side: the format of the return was already fixed, and now the filer is fixed too.
Who is affected, and who is not
The obligation only reaches groups above the EUR 750 million threshold. A standalone UAE company, a family business or a regional group below that revenue level is not a constituent entity for Pillar Two purposes and files nothing under this decision. Its obligations remain the standard 9% corporate tax regime, including the annual return described in our guide on the first UAE corporate tax return and the AED 10,000 penalty waiver.
For large groups the perimeter is wider than many assume. A UAE subsidiary of a foreign group is a constituent entity even if it is small in absolute terms, and so is a UAE branch or permanent establishment of a foreign group member. Free zone companies are not carved out: a free zone entity that belongs to an in-scope group is a constituent entity located in the UAE and falls under the filing rule, regardless of whether it benefits from the 0% qualifying free zone rate under the corporate tax law. Joint ventures are treated separately in the decision because under the GloBE Rules they are consolidated by the equity method rather than line by line, and the UAE rule now makes clear that the joint venture and its subsidiaries file in their own right. The only exclusion named in the decision is the investment entity, which mirrors the special treatment investment entities receive across the GloBE Rules.
Checklist: what an in-scope group should do now
- Confirm scope: check consolidated revenue against the EUR 750 million test for two of the four preceding fiscal years, including cases where a merger or acquisition brought the group over the line.
- Map every UAE presence: subsidiaries, free zone entities, branches and permanent establishments, joint ventures and their subsidiaries, and any partnership or trust that could qualify as a reverse hybrid entity under UAE law.
- Choose the filing route: one designated local entity for all UAE members or entity-by-entity filing, and document the authorisation of the designated entity.
- Register the group’s UAE members for Top-up Tax in EmaraTax, using the domestic designated filing entity route where a single filer is chosen.
- Align the data flow with the parent company: the UAE return follows the OECD GloBE Information Return template adopted by Ministerial Decision No. 96 of 2026, so the UAE figures must reconcile with the group-level return prepared abroad.
- Put the dates in the calendar: 18 months after the end of the first in-scope fiscal year, 15 months for later years, alongside the corporate tax return and the e-invoicing rollout in 2026-2027.
How Atlant Capital can help
Atlant Capital works with foreign groups and founders that establish a UAE presence, from company setup in a free zone or on the mainland to corporate bank account opening, licensing and residency. For a multinational group that question now includes the Pillar Two filing position of the new entity: whether it will be a constituent entity, whether a joint venture structure is involved, and which UAE company should act as the designated local entity. We do not prepare GloBE calculations, which belong to the group’s tax advisers and auditors, but we structure the UAE entity so that its ownership, licence and accounting set-up fit the reporting the group will have to make, and we coordinate the registration steps with the FTA and the relevant free zone.
Conclusion
Ministerial Decision No. 133 of 2026 does not change how much tax a multinational pays in the UAE. It changes who has to speak to the FTA and how. Every UAE constituent entity, joint venture, joint venture subsidiary and UAE-law reverse hybrid entity of an in-scope group owes a Pillar Two Information Return for fiscal years from 2025-01-01, and a group can concentrate that duty in a single designated local entity. With the return format fixed by Ministerial Decision No. 96 of 2026, registration open in EmaraTax and the first transitional deadline of 18 months after year-end, groups with a calendar 2025 fiscal year have until 2027-06-30 to file, and now know which of their UAE companies must do it.
FAQ
Who must file the Pillar Two Information Return in the UAE?
Under Ministerial Decision No. 133 of 2026, every constituent entity located in the UAE (other than an investment entity), every joint venture and joint venture subsidiary located in the UAE, and every stateless constituent entity that is a reverse hybrid entity created under UAE law must file the return with the Federal Tax Authority. The rule applies only to members of multinational groups within the scope of the UAE Top-up Tax, that is groups with consolidated revenue of EUR 750 million or more, for fiscal years starting on or after 2025-01-01.
Can one UAE company file the Pillar Two return for the whole group?
Yes. The decision allows a designated local entity to submit the Pillar Two Information Return on behalf of the other UAE constituent entities, joint ventures and joint venture subsidiaries of the group. Groups that prefer to file entity by entity may still do so. The FTA’s EmaraTax registration for Top-up Tax also provides a domestic designated filing entity route for the same purpose.
Does Ministerial Decision No. 133 of 2026 introduce a new tax?
No. The 15% domestic minimum top-up tax was introduced by Cabinet Decision No. 142 of 2024 and applies to fiscal years starting on or after 2025-01-01. Ministerial Decision No. 133 of 2026 only specifies which UAE entities are responsible for filing the Pillar Two Information Return under that framework. Companies outside multinational groups above the EUR 750 million threshold are not affected and continue to follow the standard 9% corporate tax rules.
When is the first Pillar Two return due in the UAE?
Cabinet Decision No. 142 of 2024 sets the Top-up Tax return and payment deadline at 15 months after the end of the fiscal year, extended to 18 months for the transitional first year. For a group whose first in-scope fiscal year is calendar 2025, that means a deadline of 2027-06-30. The Ministry of Finance announcement of Ministerial Decision No. 133 of 2026 did not set a separate deadline for the information return, so groups should follow the Top-up Tax timeline and any further FTA guidance.
