UAE Spells Out New Tax Filing Rules For Multinational Firms
Ministerial Decision No. 133 of 2026 specifies the filing requirements under Cabinet Decision No. 142 of 2024, which governs the Top-Up Tax imposed on multinational enterprises operating in the country.
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The move is part of the UAE's ongoing implementation of the Pillar Two rules and is aimed at giving multinational enterprises greater clarity and certainty over their reporting obligations, while reinforcing the country's commitment to international tax transparency.
The decision supports the consistent application of the Pillar Two Global Anti-Base Erosion (GloBE) Rules developed under the OECD/G20 Inclusive Framework.
Who needs to fileUnder the new rules, three categories of entities operating in the UAE are required to submit a Pillar Two Information Return to the Federal Tax Authority:
- Every constituent entity located in the UAE, apart from investment entities
Every joint venture and JV subsidiary located in the UAE
Every stateless constituent entity that is a reverse hybrid entity formed under UAE lawThe return can be filed directly by the Constituent Entity, Joint Venture or JV Subsidiary itself, or alternatively by a Designated Local Entity acting on its behalf.
The decision takes effect for financial years starting on or after January 1, 2025.
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