Compliance
Navigating UAE’s New Pillar Two Filing Requirements: What Multinationals Must Know
Discover how UAE’s recent decision mandates specific entities to file Pillar Two Information Returns and how businesses can align to avoid penalties and streamline compliance.
By NomadicTax Research Team • 5-8 min read • August 28, 2026
## What is Pillar Two and Why It Matters
The UAE’s *Top-Up Tax* regime implements Pillar Two of the OECD/G20 framework. Its goal: ensure large multinationals pay a minimum effective tax rate, avoiding profit shifting and tax base erosion. In August 2026, the UAE issued **Ministerial Decision No. 133 of 2026**, clarifying which entities must file an information return under these rules. ([mof.gov.ae](https://mof.gov.ae/en/news/ministry-of-finance-issues-ministerial-decision-on-requirements-for-filing-pillar-two-information-return/?utm_source=openai))
## Who Must File – A Closer Look
Entities required under the new decision include:
- **Each Constituent Entity**, except investment entities, located in the UAE.
- **Joint Ventures (JVs) and JV Subsidiaries** situated in the UAE.
- **Stateless Constituent Entities** that qualify as **Reverse Hybrid Entities** under UAE law. ([mof.gov.ae](https://mof.gov.ae/en/news/ministry-of-finance-issues-ministerial-decision-on-requirements-for-filing-pillar-two-information-return/?utm_source=openai))
Also noteworthy: the Information Return can be filed by the entity itself or by a **Designated Local Entity** acting on its behalf. The provisions go live for **fiscal years starting on or after 1 January 2025**. ([mof.gov.ae](https://mof.gov.ae/en/news/ministry-of-finance-issues-ministerial-decision-on-requirements-for-filing-pillar-two-information-return/?utm_source=openai))
## Action Steps: Compliance Checklist
Here’s how multinational businesses operating in the UAE can prepare:
1. **Review Entity Structure**
- Identify all Constituent Entities, JVs, JV Subsidiaries, and any Reverse Hybrids. Confirm their tax status.