Ministerial Decision No. 133 of 2026 identifies the persons required to file the Pillar Two Information Return with the Federal Tax Authority. It introduces no new tax: it states who carries the filing obligation within an existing regime, for financial years beginning on or after 1 January 2025.
What happened
The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, identifying the persons required to file the Pillar Two Information Return with the Federal Tax Authority (FTA). Pillar Two is the 15% global minimum taxation regime agreed at OECD level and adopted in the UAE by Cabinet Decision No. 142 of 2024; the Pillar Two Information Return is the informational filing through which that regime is reported. Under the decision, the following are obliged to file: every constituent entity — that is, every entity forming part of the in-scope group — located in the UAE, excluding investment entities; every joint venture and its subsidiaries located in the UAE; and every stateless constituent entity that is a reverse hybrid entity incorporated under UAE law.
What changes in practice
No new tax is introduced and no thresholds change: what changes is certainty over who signs the return. Previously the obligation sat with the regime in general terms; it is now written down which entity in the group discharges it. The rules apply to financial years beginning on or after 1 January 2025, so for a group on a calendar year the first affected period is the one ending 31 December 2025. This is the final piece after registration for the regime opened on EmaraTax, the FTA's online tax portal: first you register, then you file.
Who it applies to
To UAE entities belonging to multinational groups above the GloBE threshold — groups with consolidated revenues exceeding EUR 750 million in at least two of the four preceding financial years. GloBE stands for Global Anti-Base Erosion, the OECD ruleset underpinning Pillar Two. The threshold excludes the large majority of owner-managed UAE companies. It does apply to any UAE entity sitting inside a multinational group of that size, and to anyone participating in UAE joint ventures of foreign groups.
The exposure
The typical exposure is assuming the filing belongs to the foreign parent and that the UAE entity has nothing to do. The decision says the opposite: the obligation can fall on the entity located in the UAE even where the controlling company sits elsewhere. In a group with several UAE entities, the mirror-image exposure is that each assumes another has already dealt with it.
What to do now
Any UAE company with a foreign parent should retrieve two data points from the parent's consolidated accounts: consolidated revenues for the last four financial years, to establish whether the group exceeds the EUR 750 million threshold, and the closing date of the first in-scope financial year. If the group is above the threshold, map every UAE entity — including joint ventures and their subsidiaries — and settle in writing, with the parent's advisers, who files the return and who signs it. That is a decision to take now, not at the deadline.
Sources
- https://mof.gov.ae/en/
- https://gulfnews.com/business/corporate-tax/uae-sets-new-tax-reporting-rules-for-multinational-companies-1.500652772
Published 27 August 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.