Compliance
Understanding the UAE’s Pillar Two Filing Obligations: Who Must Report?
With UAE’s new Decision No. 133 of 2026 coming into effect, multinationals operating in the country need to know exactly **who is required to file** a Pillar Two Information Return and what this means for tax compliance.
By NomadicTax Research Team • 5-8 min read • September 10, 2026
## What’s New Under Decision No. 133 of 2026
On **August 25, 2026**, the UAE Ministry of Finance issued **Ministerial Decision No. 133 of 2026**, defining which entities operating in the UAE must file a **Pillar Two Information Return** under the Top-Up Tax regime set by **Cabinet Decision No. 142 of 2024**. This aligns with the global **Pillar Two (GloBE) Rules** agreed under the OECD/G20 Inclusive Framework.([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))
## Entities Required to File
Under the new rule, the following UAE-based entities must file the Information Return for fiscal years starting **on or after January 1, 2025**:
- **Constituent Entities** located in the UAE, except any **Investment Entity**.
- **Joint Ventures (JVs)** and **JV Subsidiaries** in the UAE.
- **Stateless Constituent Entities** that are **Reverse Hybrid Entities** under UAE law.
You can file either directly or via a **Designated Local Entity** on behalf of eligible entities.([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))
## Why This Matters: Key Implications
- **Corporate Reporting**: Multinationals with UAE operations must determine whether their subsidiaries, JVs, or hybrid structures fall within this requirement.
- **Tax Certainty**: Clear definitions help reduce ambiguity and risk of non-compliance with international tax norms.
- **Effective Dates**: Fiscal years **beginning January 1, 2025** trigger obligations. Early planning is essential.([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))
## Actionable Steps for Multinational Entities
1. **Review your legal structure**: Are you an Investment Entity? A Reverse Hybrid? Do you have JVs? Probate your fiscal year start date.
2. **Assign Responsibility**: Decide whether you will file directly or via a designated local entity.
3. **Data Gathering**: Collect financial, entity ownership, and intercompany transaction information required by Pillar Two rules.
4. **Check Systems and Processes**: Reporting under Pillar Two involves cross-border data; ensure your accounting and tax systems are ready.
5. **Engage Advisors**: OECD-aligned Pillar Two compliance is complex; consider engaging firms with regional expertise. PWC, EY, Deloitte, KPMG have published guides on implementation under Gulf contexts.
## Example Scenario
**Company A**, a UAE-based Scope 1 company, has a JV (Company B) with a foreign partner. Company A needs to assess three alternatives:
- File as the **Constituent Entity** (Company A).
- Determine whether the JV (Company B) must file (if it's treated as a JV or JV Subsidiary).
- If there's a Reverse Hybrid entity without clear residence, assess the stateless entity rules.
If Company B meets thresholds, then both A and B have reporting obligations—or a designated local entity must report. Early days, but non-compliance may trigger penalties or reputational harm.
## Conclusion
Decision No. 133 of 2026 is a major step in the UAE’s alignment with international tax norms. Multinationals must **identify filing obligations**, **prepare financial and ownership data**, and **integrate reporting** seamlessly into their tax compliance calendar. The deadline date of January 1, 2025 (for fiscal year start) means many are already operating under the new standards. The time for reactive planning has passed— companies should already be in the process of ensuring compliance.