IntroductionThe UAE has issued Ministerial Decision No. 133 of 2026, clarifying which entities are required to file the Pillar Two Information Return (Pillar Two GIR) with the Federal Tax Authority (FTA) under the UAE’s Pillar Two framework. The Decision was issued on 3 August 2026 and applies to fiscal years beginning on or after 1 January 2025.
Who Is Required to File the Pillar Two Information Return?
Under Article 2 of Ministerial Decision No. 133 of 2026, the following entities located or established in the UAE are required to file a Pillar Two Information Return with the FTA, subject to the conditions provided in the Decision.
1. UAE Constituent Entities
Each Constituent Entity located in the UAE is required to file the Pillar Two Information Return, except for Investment Entities.
2. Joint Ventures and JV Subsidiaries
The requirement also applies to each Joint Venture (JV) and JV Subsidiary located in the UAE.
3. Stateless Constituent Entities
A Stateless Constituent Entity that is a Reverse Hybrid Entity created under UAE laws is also included within the filing requirement.
Can Another Entity File the Return?
Yes. The Pillar Two Information Return does not necessarily have to be filed directly by each individual UAE entity. The Decision allows the return to be filed by the relevant Constituent Entity, Joint Venture or JV Subsidiary, or by a Designated Local Entity on its behalf.
When Is a UAE Entity Not Required to File Directly?
A UAE Constituent Entity, Joint Venture or JV Subsidiary may not be required to file the Pillar Two Information Return with the FTA where the required 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 by the Designated Filing Entity located in such a jurisdiction.
Notification Requirement
Where the above condition applies, the relevant UAE entity or Designated Local Entity must notify the FTA of the identity and location of the entity or entities that filed the Pillar Two Information Return.
Effective Date and Fiscal Years Covered
Ministerial Decision No. 133 of 2026 applies to fiscal years starting on or after 1 January 2025. The Decision was issued on 3 August 2026 and becomes effective from the date of issuance.
What Does This Mean for Multinational Groups in the UAE?
Multinational groups operating in the UAE should assess whether their UAE entities qualify as Constituent Entities, whether any UAE Joint Ventures or JV Subsidiaries are within scope, whether a Designated Local Entity will handle the filing, whether the relevant Ultimate Parent Entity or Designated Filing Entity has already filed the required return in another jurisdiction, whether a Qualifying Competent Authority Agreement is in effect for the relevant Reporting Fiscal Year, and whether notification to the FTA is required.
Key Takeaway
Ministerial Decision No. 133 of 2026 clarifies the UAE filing obligations for the Pillar Two Information Return. While certain UAE entities may be able to rely on a return filed by an overseas Ultimate Parent Entity or Designated Filing Entity, the applicable conditions and notification requirements must still be considered. For multinational groups operating in the UAE, reviewing the group structure, filing responsibilities and cross-border reporting arrangements is essential to ensure compliance with the UAE Pillar Two framework.