UAE tax filing rules have changed for certain multinational companies, with new requirements explaining who must submit Pillar Two information to authorities.
ABU DHABI: The UAE has announced new tax filing requirements for certain multinational companies operating in the country, giving businesses clearer guidance on who needs to report information under the Pillar Two tax system. The new UAE tax filing rules are part of the country’s efforts to improve international tax transparency and make reporting requirements easier for affected companies to understand.
The Ministry of Finance issued Ministerial Decision No. 133 of 2026 on August 26, setting out which entities must file a Pillar Two Information Return with the Federal Tax Authority. Importantly, this does not mean that every UAE resident or business now has a new tax return to complete. The decision mainly affects large multinational groups that fall under the UAE’s Top-up Tax regime, so most individuals and smaller businesses should not be directly affected by this particular announcement.
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Under the decision, each Constituent Entity located in the UAE will generally be required to file the information return, although investment entities are excluded. Joint Ventures and JV Subsidiaries located in the UAE are also covered, along with certain Stateless Constituent Entities that are Reverse Hybrid Entities created under UAE law. While these terms may sound complicated, the basic idea is that qualifying multinational businesses must provide authorities with the information needed to check that their tax obligations are being handled correctly.
Companies will also have some flexibility when it comes to filing. A qualifying Constituent Entity, Joint Venture or JV Subsidiary can submit the return directly, or a Designated Local Entity can file it on its behalf. This should make it easier for multinational groups with several businesses in the UAE to organise their reporting through one designated local entity where permitted.
The UAE tax filing rules support the country’s implementation of the OECD/G20 Pillar Two Global Anti-Base Erosion rules, also known as GloBE. These international rules are designed to make sure large multinational groups pay a minimum level of tax across the countries where they operate. For companies covered by the system, the latest UAE decision provides more certainty about which local entities are responsible for supplying the required information.
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The new requirements apply to fiscal years beginning on or after January 1, 2025. Businesses covered by the Top-up Tax regime should therefore check their company structures, confirm which entities have filing responsibilities and make sure their reporting arrangements meet the new requirements.
Impact to expect
For most UAE residents and smaller businesses, there should be no direct change from this announcement. The main impact will be on qualifying multinational companies, which now have clearer instructions on who must file Pillar Two information and how those returns can be submitted.
