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Tax Planning

Planning for UAE Pillar Two Reporting: What Multinationals Need to Do Now

With the UAE’s recent introduction of explicit Pillar Two reporting requirements under its Top-Up Tax regime, multinationals need to understand which entities are in scope, timing, and data obligations to avoid penalties.

By NomadicTax Research Team · 5-8 min read

Overview

The UAE has issued Ministerial Decision No. 133 of 2026, which defines which entities must file a Pillar Two Information Return under Cabinet Decision No. 142 of 2024 (the UAE’s Top-Up Tax regime).(mof.gov.ae)

This article digs into what this means for multinationals doing business in or via UAE-based entities — and what you should do now to comply.

Who Has to File

According to the new decision (applicable from fiscal years starting on or after 1 January 2025), the following entities are required to file a Pillar Two Information Return:

  • Each Constituent Entity located in UAE (excluding Investment Entities)
  • Each Joint Venture and JV Subsidiary located in UAE
  • Stateless Constituent Entities that are reverse-hybrid entities under UAE law

These entities may file the return directly or via a Designated Local Entity on their behalf.(mof.gov.ae)

Compliance Timeline & Data Requirements

ItemDetail
Effective dateFiscal years starting on or after 1 Jan 2025
Key data requiredProfit & loss, constituent entity structure, intra-group transactions, income reports across jurisdictions
Who can fileIndividual Constituent Entities or Designated Local Entity

Actionable Steps for Multinations Now

  1. Identify all in-scope entities: Constituent Entities, JVs, reverse hybrids based in UAE. Map out structures.
  2. Review data gathering procedures: Ensure systems can capture actions across the group needed for GloBE reporting – revenue, earnings, taxes paid abroad.
  3. Determine filing route: Decide whether the UAE entities file directly or appoint a Designated Local Entity. Requires clarity and internal agreement.
  4. Check consistency with group reporting elsewhere: Pillar Two rules affect liabilities in multiple jurisdictions; information may need to match group financials.
  5. Assess risk & penalties: Where filings are inaccurate or late, consequences under Top-Up Tax or corporate tax laws may follow.

Example Scenario

Acme Global Ltd., an MNE headquartered outside UAE, owns:

  • Acme Manufacturing UAE LLC (Constituent Entity)
  • Acme JV Arabia (Joint Venture)
  • Acme Investment Trust, a reverse hybrid entity established under UAE law

Under MD 133:

  • Both the Manufacturing UAE entity and the JV must file the Pillar Two Information Return.
  • The Trust, if reverse-hybrid, is also required.
  • All three can file directly or via a designated entity.

Why This Matters for Tax Planning

  • Cash flow impact: Pillar Two rules impose minimum effective tax rates; topline rates can trigger additional tax liabilities or refusals of deductions elsewhere.
  • Deferred compliance cost: Data system upgrades, consolidated reporting, and cross-border agreements take time.
  • Reputation & transparency: Clear, accurate reporting is now being watched more closely by tax authorities globally.

Key Takeaways

  • The UAE’s Pillar Two Information Return requirement is active for fiscal years starting 1 Jan 2025.
  • Entities in UAE that are part of groups must assess whether they fall in scope.
  • Early preparation—structure reviews, reporting systems—will make compliance smoother.
  • Consult specialized advisors, especially in complex cross-border groups.

Find out if your entities are in scope now—begin internal audits and establish documentation trails. The deadline may be close.

Sources

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