The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026: the document clarifies which entities within multinational enterprise (MNE) groups operating in the Emirates are required to file the Pillar Two Information Return with the Federal Tax Authority. It does not introduce a new tax — it pins down the filing scope and the mechanism within the already-live Cabinet Decision No. 142 of 2024 on the Top-Up Tax for MNEs. It applies to Fiscal Years beginning on or after 1 January 2025. Below: who is covered, how the return is submitted and what UAE-based businesses should do now.
What MD 133/2026 does
According to the Ministry of Finance UAE, the new ministerial decision solves one concrete problem: define the population of entities required to file the Pillar Two Information Return and the mechanism for filing. The Decision is issued as part of the UAE's implementation of the Global Anti-Base Erosion (GloBE) Rules of the OECD/G20 Inclusive Framework — the same Pillar Two project on a global minimum level of taxation for large multinational groups.
The legal frame was already in place: Cabinet Decision No. 142 of 2024 established the Top-Up Tax for multinational enterprises operating in the UAE. MD 133/2026 is the next step — the detail of who inside such an MNE group reports to the FTA, and through what mechanism.
Three categories of entities required to file
Directly from the Decision — the Pillar Two Information Return is filed with the Federal Tax Authority by:
- Each Constituent Entity located in the UAE — excluding any Investment Entity;
- Each Joint Venture and JV Subsidiary located in the UAE;
- Each Stateless Constituent Entity that is a Reverse Hybrid Entity, created in accordance with UAE laws.
In the Pillar Two context, a Constituent Entity is an entity that forms part of an MNE group covered by the GloBE Rules. The inclusion of Joint Ventures and their subsidiaries means the reporting perimeter is not limited to the conventional corporate ladder of a group: JVs and JV subsidiaries also sit inside the filing scope. Reverse Hybrid Entities are addressed separately — a specific type of structure often used in cross-border tax planning. Investment Entities are expressly excluded from this filing obligation.
Filing mechanism: entity itself, or via a Designated Local Entity
The Decision allows two filing paths for the Pillar Two Information Return:
- directly — by the Constituent Entity, Joint Venture or JV Subsidiary itself;
- via a Designated Local Entity — a specifically nominated UAE-based entity that files on behalf of the relevant entities in the group.
In practice, this lets an MNE group centralise filing through a single UAE entity rather than requiring every covered entity to deal with the FTA independently. For large groups with a broad UAE footprint, this materially reduces the compliance load and removes the risk of divergent filings on the same underlying data.
From when it applies
Per the Ministry of Finance text, MD 133/2026 applies to Fiscal Years beginning on or after 1 January 2025. That anchors the filing obligation to periods already started under the Top-Up Tax regime set by Cabinet Decision No. 142 of 2024.
For groups on a calendar fiscal year, the first reporting period is 2025, with the Pillar Two Information Return due within the deadlines set by the Federal Tax Authority. The exact deadline mechanics, forms and electronic filing channel are set out in separate FTA guidance — MNE advisers should track FTA publications in parallel.
What this means for business in the UAE
To be clear up front: MD 133/2026 directly affects only large multinational groups that fall within the Pillar Two GloBE scope. A local SME that is not part of such a group does not fall under this Decision — for them, the standard 9% corporate tax above the AED 375,000 threshold continues to apply, and the basic criteria of who pays and at what rate are laid out in «UAE 9% corporate tax: who pays».
For MNE groups operating in the UAE, the practical next-cycle steps are:
- Map UAE entities. Identify exactly which of them fall into the three categories in the Decision (Constituent Entities, JV/JV Subsidiaries, Reverse Hybrid Entities) and which are expressly excluded (Investment Entities).
- Designated Local Entity call. Take the decision formally and document the delegation of the filing obligation to a nominated UAE entity.
- Fiscal years from 1 January 2025. Prepare Pillar Two Information Return data for the current period in line with GloBE requirements and the group's internal accounting systems.
- Track FTA guidance. Deadlines, forms and electronic filing channels are anchored by the regulator through separate publications — monitor in the ordinary course.
In short
The Ministry of Finance UAE has issued Ministerial Decision No. 133 of 2026 — the Pillar Two Information Return rules within the already-live Cabinet Decision No. 142 of 2024 (Top-Up Tax for MNEs). Three categories of entities are required to file: Constituent Entities (except Investment Entities), Joint Ventures / JV Subsidiaries, and Reverse Hybrid Entities. Filing is either direct or via a Designated Local Entity. It applies to fiscal years beginning on or after 1 January 2025. The Decision does not introduce a new tax — it pins down the reporting.
Primary source — Ministry of Finance UAE, official announcement on mof.gov.ae. Corroborating report — Gulf News, «UAE sets new tax reporting rules for multinational companies».
