New Pillar Two filing rules clarify which multinational entities must report to FTA

The UAE Ministry of Finance has issued Ministerial Decision No. 133 of 2026, which specifies which entities within multinational groups must file a Pillar Two Information Return with the Federal Tax Authority under the country's Top-up Tax framework.

Three categories of entities are required to file: each Constituent Entity located in the UAE (except Investment Entities); each Joint Venture and Joint Venture Subsidiary located in the UAE; and each Stateless Constituent Entity that is a Reverse Hybrid Entity created under UAE laws.

A Constituent Entity broadly refers to an entity that forms part of a multinational enterprise group covered by the Pillar Two framework. The inclusion of Joint Ventures and their subsidiaries means the reporting requirement extends beyond conventional corporate structures.

Multinational groups can file directly or designate a local UAE entity to submit the return on their behalf, allowing centralised filing rather than requiring every covered entity to handle submission independently.

The reporting requirements form part of the UAE's implementation of the OECD/G20 Inclusive Framework's Pillar Two Global Anti-Base Erosion (GloBE) Rules, designed to establish a minimum level of taxation for large multinational enterprises across jurisdictions where they operate.