Ministry of Finance outlines Pillar Two reporting requirements under the global minimum tax framework
Abu Dhabi: The Ministry of Finance has issued Ministerial Resolution No. (133) of 2026 concerning entities required to submit a Pillar Two Information Return under Cabinet Resolution No. (142) of 2024 on the imposition of a top-up tax on multinational enterprises.
The resolution forms part of the UAE’s ongoing implementation of the OECD/G20 Global Anti-Base Erosion (GloBE) Rules, commonly known as Pillar Two, and reinforces the country’s commitment to international tax transparency while providing greater certainty and clarity to multinational groups regarding their reporting obligations.
The ministerial decision establishes reporting requirements for multinational enterprises operating in the UAE under the top-up tax regime and supports the consistent application of the global minimum tax framework.
Under the resolution, entities required to file a Pillar Two Information Return with the Federal Tax Authority (FTA) include:
- Every constituent entity located in the UAE, except investment entities.
- Every joint venture and joint venture subsidiary located in the UAE.
- Every stateless constituent entity that is a reverse hybrid entity established under UAE laws.
- The resolution also permits the Pillar Two Information Return to be submitted by:
- The constituent entity itself.
- The joint venture or joint venture subsidiary.
- A designated local entity acting on behalf of the relevant entity.
The Ministry of Finance said the measure is intended to facilitate compliance and ensure that reporting obligations are aligned with international tax standards adopted under the OECD and G20 framework.
The ministerial resolution applies to financial years beginning on or after 1 January 2025, marking another step in the UAE’s implementation of the global minimum tax regime for large multinational groups.
Source: Emirates 24|7