UAE Issues Ministerial Decision on Pillar Two Information Return Filing Rules

The United Arab Emirates has issued Ministerial Decision No. 133 of 2026, establishing practical guidelines for submitting the Pillar Two Information Return under the country's Domestic Minimum Top-up Tax regime, law firm Trowers & Hamlins reported. The procedural decision supplements Cabinet Decision No. 142 of 2024 and aligns with the Organisation for Economic Co-operation and Development's global minimum tax framework.

The rules apply to multinational enterprise groups with annual consolidated revenues of at least 750 million euros in at least two of the four preceding fiscal years. The decision applies to fiscal years beginning on or after 1 January 2025, meaning groups operating on a calendar-year basis face a first reporting period ending 31 December 2025, with returns due within 15 months after the end of each fiscal year.

Under the framework, filing obligations extend to each UAE-based constituent entity (excluding investment entities), joint ventures and their subsidiaries, as well as stateless reverse hybrid entities established under UAE law. To streamline compliance, groups are permitted to designate a single UAE entity to submit the return on behalf of all local operations.

A local filing exemption is available if the return has already been submitted by the group's Ultimate Parent Entity or a Designated Filing Entity in an overseas jurisdiction that maintains an active Qualifying Competent Authority Agreement with the UAE. However, under Article 2(4), groups relying on overseas filings must still submit a notification to the Federal Tax Authority identifying the responsible foreign filing entity.