On 3 August 2026, the UAE Ministry of Finance published Ministerial Decision No. 133 of 2026, which identifies the entities required to file a Pillar Two Information Return (“GIR”) with the Federal Tax Authority (“FTA”) under Cabinet Decision No. 142 of 2024 on the Top-Up Tax on Multinational Enterprises. The Decision also confirms the circumstances in which a UAE entity is relieved of its own filing obligation, and the related notification duty.
Who Must File
Subject to the exceptions below, the following persons located in the UAE must file a Pillar Two Information Return conforming to Article 15 of the Annexure to Cabinet Decision No. 142 of 2024:
Each Constituent Entity located in the UAE, excluding any Investment Entity;
Each Joint Venture and JV Subsidiary located in the UAE; and
Each Stateless Constituent Entity that is a Reverse Hybrid Entity created under UAE law.
Who May File on Their Behalf
The Return may be filed either by the Constituent Entity, Joint Venture or JV Subsidiary itself, or by a Designated Local Entity acting on its behalf.
Relief from Local Filing
A UAE Constituent Entity, Joint Venture or JV Subsidiary is not required to separately file with the FTA where an Article 15 conforming Return has already been filed by:
the Ultimate Parent Entity, located in a jurisdiction that has a Qualifying Competent Authority Agreement (“QCAA”) in effect with the UAE for the relevant Reporting Fiscal Year; or
The Designated Filing Entity, located in a jurisdiction that has a QCAA in effect with the UAE for the relevant Reporting Fiscal Year.
Where this relief applies, the UAE entity (or its Designated Local Entity) must still notify the FTA of the identity and location of the entity or entities actually filing the Return.
Summary Table
| Scenario | Local Filing Required? | Notification to FTA? |
| No QCAA in place with UPE/Designated Filing Entity jurisdiction | Yes – by the UAE entity or a Designated Local Entity | Not applicable |
| QCAA in effect and Return filed by UPE / Designated Filing Entity in their jurisdiction | No | Yes – identify who filed and where |
| Investment Entity located in the UAE | Excluded from this filing obligation | Not applicable |