UAE spells out new tax filing rules for multinational firms

27/08/2026 03:21 AST

The UAE's Ministry of Finance has issued a new decision setting out which entities must file Pillar Two Information Returns, as the UAE continues rolling out its global minimum tax framework for multinational enterprises.

Ministerial Decision No. 133 of 2026 specifies the filing requirements under Cabinet Decision No. 142 of 2024, which governs the Top-Up Tax imposed on multinational enterprises operating in the country.

The move is part of the UAE's ongoing implementation of the Pillar Two rules and is aimed at giving multinational enterprises greater clarity and certainty over their reporting obligations, while reinforcing the country's commitment to international tax transparency.

The decision supports the consistent application of the Pillar Two Global Anti-Base Erosion (GloBE) Rules developed under the OECD/G20 Inclusive Framework.

Who needs to file
Under the new rules, three categories of entities operating in the UAE are required to submit a Pillar Two Information Return to the Federal Tax Authority:

Every constituent entity located in the UAE, apart from investment entities

Every joint venture and JV subsidiary located in the UAE

Every stateless constituent entity that is a reverse hybrid entity formed under UAE law

The return can be filed directly by the Constituent Entity, Joint Venture or JV Subsidiary itself, or alternatively by a Designated Local Entity acting on its behalf.

The decision takes effect for financial years starting on or after January 1, 2025.


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