Ministerial Decision No. 133 of 2026 identifies the UAE entities responsible for filing the Pillar Two Information Return and clarifies when local entities may rely on a filing made elsewhere within the group.

The UAE's Pillar Two framework was introduced through Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises. As part of that framework, Article 15 of the Annexure requires in-scope multinational groups to prepare and submit a Pillar Two Information Return containing information relevant to the application of the Global Anti-Base Erosion (GloBE) Rules.

The Pillar Two Information Return follows the OECD GloBE Information Return framework and serves as the primary reporting mechanism through which multinational groups provide information relevant to the operation of the GloBE Rules. Under Article 15, the return is generally required to be submitted within 15 months after the end of the relevant Reporting Fiscal Year.

Ministerial Decision No. 133 of 2026 does not introduce a new filing obligation. Instead, it clarifies which UAE entities are responsible for filing the Pillar Two Information Return with the Federal Tax Authority (FTA), when a local filing obligation may be satisfied through a filing made elsewhere within the group, and the notification requirements that apply in such cases.

What is the Pillar Two Information Return?

The Pillar Two Information Return is the primary reporting mechanism through which in-scope multinational groups provide information required to assess compliance with the GloBE Rules. The return is based on the OECD GloBE Information Return framework and includes information relating to the group structure, jurisdictional calculations and Pillar Two tax positions.

The Information Return is distinct from the calculation of any Top-Up Tax liability. Instead, it provides tax authorities with the information necessary to understand how the GloBE Rules apply across the multinational group and to assess whether any Top-Up Tax may arise.

What entities are required to file a Pillar Two Information Return?

Subject to certain exceptions, the following UAE entities are required to file a Pillar Two Information Return with the FTA:

·        UAE Constituent Entities, excluding Investment Entities.

·        UAE Joint Ventures and JV Subsidiaries.

·        Stateless Constituent Entities that qualify as Reverse Hybrid Entities under UAE law.

The return may be submitted directly by the relevant entity or by a Designated Local Entity acting on its behalf.

Can a UAE entity rely on a filing made elsewhere?

Yes. A UAE Constituent Entity, Joint Venture or JV Subsidiary is not required to file a Pillar Two Information Return locally where a qualifying return has already been submitted by:

·        The Ultimate Parent Entity (UPE).

·        A Designated Filing Entity (DFE).

This exemption applies where the filing entity is located in a jurisdiction that has a Qualifying Competent Authority Agreement (QCAA) in effect with the UAE for the relevant Reporting Fiscal Year.

This approach is consistent with the broader Pillar Two objective of reducing duplicate reporting obligations where information can be exchanged through agreed international mechanisms.

What notification requirements apply?

Importantly, relief from local filing does not eliminate all compliance obligations.

Where a UAE entity relies on a filing made by a UPE or DFE in another jurisdiction, the UAE entity, or its Designated Local Entity, must notify the FTA of the identity and location of the entity submitting the Pillar Two Information Return.

For many groups, this notification requirement may become one of the most significant practical aspects of the Decision, requiring coordination between UAE entities and the group’s global tax function.

What does the Decision not change?

Ministerial Decision No. 133 of 2026 does not amend the substantive Pillar Two rules already established under Cabinet Decision No. 142 of 2024.

In particular, the Decision does not:

·        Change the scope of Pillar Two.

·        Introduce new revenue thresholds.

·        Modify the content of the Pillar Two Information Return.

·        Alter the calculation of Top-Up Tax under the UAE Pillar Two framework.

Instead, its purpose is to clarify filing responsibilities and reporting governance within multinational groups.

When does the Decision apply?

Ministerial Decision No. 133 of 2026 applies to Fiscal Years beginning on or after 1 January 2025. The Decision became effective upon its issuance on 3 August 2026.

What should multinational groups do now?

Multinational groups with UAE operations should consider:

·        Identifying all UAE entities that fall within the Pillar Two perimeter.

·        Confirming whether the Pillar Two Information Return will be filed locally or by another group entity.

·        Determining whether a Qualifying Competent Authority Agreement is available for the relevant Reporting Fiscal Year.

·        Establishing internal governance procedures for notification to the FTA.

·        Coordinating Pillar Two compliance responsibilities between UAE entities and the group’s global tax function.

·        Maintaining appropriate documentation supporting the filing approach adopted by the group and any reliance on a filing made outside the UAE.

·        Reviewing timelines for the first Pillar Two Information Return and ensuring data collection processes are aligned with the OECD GloBE Information Return requirements.

Altair Tax Insight

Ministerial Decision No. 133 of 2026 provides welcome clarity on a key operational aspect of the UAE Pillar Two framework: identifying which entity is responsible for filing the Pillar Two Information Return and when local filing obligations may be satisfied through a filing made elsewhere within the group.

While the technical mechanics of Pillar Two have received significant attention since the introduction of Cabinet Decision No. 142 of 2024, this latest Decision highlights an equally important aspect of compliance: governance. Multinational groups must not only determine whether they fall within scope, but also establish clear internal responsibilities for filing, notification and information management.

The Decision also serves as a reminder that the Pillar Two Information Return is a standalone compliance obligation, based on the OECD GloBE Information Return framework and generally due within 15 months after the end of the relevant Reporting Fiscal Year. As groups move from technical Pillar Two assessments to operational implementation, early planning and clear ownership of reporting responsibilities will be critical.

For many groups, the key challenge will not be calculating the Top-Up Tax itself, but ensuring that the appropriate entities have been identified, the correct filing approach has been adopted and the necessary reporting procedures are in place before the first Pillar Two reporting obligations arise.