UAE sets new tax reporting rules for multinational companies

Dubai: The UAE Ministry of Finance has issued new rules setting out which entities within multinational groups must file information with the Federal Tax Authority under the country's Pillar Two corporate tax framework.

Ministerial Decision No. 133 of 2026 specifies the entities required to file a Pillar Two Information Return under Cabinet Decision No. 142 of 2024, which introduced a Top-up Tax on multinational enterprises.

The rules apply to fiscal years beginning on or after January 1, 2025.

In simple terms, the information return is part of the reporting system used to determine how the UAE's Pillar Two rules apply to large multinational groups and their entities operating in the country.

The latest decision does not introduce a new Top-up Tax. Instead, it clarifies which entities have responsibility for filing the information required under the existing regime.

Who needs to file?

Under the decision, three categories of entities are required to file a Pillar Two Information Return with the Federal Tax Authority.

These are each Constituent Entity located in the UAE, except for Investment Entities; each Joint Venture and Joint Venture Subsidiary located in the UAE; and each Stateless Constituent Entity that is a Reverse Hybrid Entity created under UAE laws.

A Constituent Entity broadly refers to an entity that forms part of a multinational enterprise group covered by the Pillar Two framework.

The inclusion of Joint Ventures and their subsidiaries means the reporting requirement is not limited to the main companies within a multinational group's conventional corporate structure.

The decision also specifically addresses certain Reverse Hybrid Entities. A Stateless Constituent Entity that qualifies as a Reverse Hybrid Entity and was created under UAE law is required to file.

Investment Entities are excluded from the filing requirement that applies to UAE-based Constituent Entities under this decision.

File directly or via UAE entity

The Ministry has also clarified how the information return can be submitted. A Constituent Entity, Joint Venture or JV Subsidiary can file its Pillar Two Information Return directly.

Alternatively, a Designated Local Entity can submit the return on its behalf. This gives multinational groups the ability to centralise the filing through a designated entity in the UAE rather than requiring every covered entity to handle the submission independently.

The decision therefore establishes both who carries a reporting obligation and the mechanism through which that obligation can be fulfilled.

Part of UAE tax framework

The reporting requirements form part of the UAE's implementation of the OECD/G20 Inclusive Framework's Pillar Two Global Anti-Base Erosion, or GloBE, Rules.

Pillar Two is an international tax framework designed to establish a minimum level of taxation for large multinational enterprise groups across the jurisdictions where they operate.

In the UAE, Cabinet Decision No. 142 of 2024 established the country's Top-up Tax framework for multinational enterprises.

Ministerial Decision No. 133 of 2026 now provides further detail on the information-reporting side of that system, giving affected multinational businesses greater clarity over which UAE entities are responsible for filing.

The Ministry said the measure supports consistent implementation of the GloBE Rules and forms part of the UAE's efforts to strengthen international tax transparency and provide multinational enterprises with greater certainty over their reporting obligations.