UAE Issues Ministerial Decision No. 133 of 2026 on Pillar Two Information Return Filing Requirements
The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, setting out which entities in the UAE are required to file the Pillar Two Information Return (PTIR) with the Federal Tax Authority (FTA).
The Decision, issued on 3 August 2026, provides greater clarity on the UAE filing obligations under Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
Importantly, the Decision applies to Fiscal Years beginning on or after 1 January 2025.
Who is required to file the Pillar Two Information Return?
Subject to the exceptions outlined in the Decision, the following entities located in the UAE are required to file a Pillar Two Information Return with the FTA:
- Constituent Entities located in the UAE, excluding Investment Entities.
- Joint Ventures (JVs) located in the UAE.
- JV Subsidiaries located in the UAE.
- Stateless Constituent Entities that are Reverse Hybrid Entities created under UAE law.
The PTIR must comply with the requirements set out in Article 15 of the Annexure to Cabinet Decision No. 142 of 2024.
Who can file the Information Return?
The UAE entity itself does not necessarily have to file the PTIR.
The Decision allows the Designated Local Entity to file the Pillar Two Information Return on behalf of the relevant Constituent Entity, Joint Venture or JV Subsidiary.
This provides multinational groups with greater flexibility in coordinating their UAE Pillar Two compliance and reporting obligations.
When is a UAE entity exempt from filing directly with the FTA?
A UAE Constituent Entity, Joint Venture or JV Subsidiary will not be required to file the Pillar Two Information Return directly with the FTA where the required return has already been filed by another group entity in a qualifying jurisdiction.
This applies where the PTIR has been filed by either:
- The Ultimate Parent Entity (UPE) 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 (DFE) located in a jurisdiction that has a QCAA in effect with the UAE for the relevant Reporting Fiscal Year.
This mechanism is designed to avoid unnecessary duplicate filing where the relevant Pillar Two information has already been submitted in another jurisdiction and can be exchanged with the UAE under an appropriate agreement.
Notification requirement remains important
Although a UAE entity may not be required to file the PTIR directly in the circumstances described above, there is still a notification requirement.
Where the overseas filing mechanism applies, the relevant UAE entity or the Designated Local Entity must notify the FTA of the identity and location of the entity or entities responsible for filing the Pillar Two Information Return.
Therefore, businesses should not interpret the exemption from local filing as eliminating their UAE notification obligations.
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 is effective from the date of issuance.
This means multinational groups with UAE operations should assess their Pillar Two reporting position for fiscal years beginning from 1 January 2025 onward.
What does this mean for UAE businesses?
The Decision provides important clarity for multinational enterprise (MNE) groups with UAE constituent entities.
Businesses should consider the following:
1. Determine whether the UAE entity falls within the scope
Groups should identify all UAE entities that qualify as Constituent Entities, Joint Ventures, JV Subsidiaries or relevant Stateless Constituent Entities.
Investment Entities are specifically excluded from the UAE filing obligation under Article 2(1)(a).
2. Identify who will file the PTIR
Groups should determine whether the return will be filed by:
- The UAE Constituent Entity, JV or JV Subsidiary;
- A Designated Local Entity; or
- An eligible Ultimate Parent Entity or Designated Filing Entity in another jurisdiction.
3. Check the QCAA position
Where the group intends to rely on an overseas filing to avoid a UAE filing, it should verify that the relevant jurisdiction has a Qualifying Competent Authority Agreement in effect with the UAE for the applicable Reporting Fiscal Year.
This is an important condition and should be assessed for each relevant fiscal year.
4. Review notification obligations
Where the PTIR is filed outside the UAE under the qualifying mechanism, the UAE entity or Designated Local Entity must ensure that the required notification is made to the FTA, including the identity and location of the filing entity.
5. Establish appropriate data and reporting processes
Pillar Two compliance requires significant financial and tax data. Groups should ensure that appropriate processes are in place to collect, validate and reconcile the information required for the PTIR.
Key takeaway
Ministerial Decision No. 133 of 2026 provides a clearer framework for determining who is responsible for filing the Pillar Two Information Return in the UAE.
While UAE Constituent Entities, Joint Ventures and JV Subsidiaries are generally within the scope of the filing requirement, the Decision allows the filing obligation to be satisfied through a Designated Local Entity or, subject to specific conditions, through an eligible overseas Ultimate Parent Entity or Designated Filing Entity.
The availability of the overseas filing mechanism depends on the existence of a Qualifying Competent Authority Agreement with the UAE, and relevant UAE entities must still comply with the associated notification requirement.
With the rules applying to fiscal years beginning on or after 1 January 2025, affected multinational groups should review their group structure, filing arrangements and reporting processes to ensure compliance with the UAE’s Pillar Two requirements.
If your group has UAE entities potentially affected by the Pillar Two reporting requirements, now is the time to review your filing position, QCAA eligibility and FTA notification obligations. XB4 can support you in assessing your compliance requirements and preparing for the relevant reporting obligations. Contact us to discuss how these rules may apply to your business.
