Abu dhabi: The Ministry of Finance has released Ministerial Decision No. 133 of 2026, detailing the entities mandated to submit the Pillar Two Information Return in line with Cabinet Decision No. 142 of 2024, which pertains to the imposition of Top-Up Tax on Multinational Enterprises.

According to Emirates News Agency, the Ministerial Decision is part of the UAE's ongoing efforts to implement the Pillar Two requirements and emphasizes the nation's dedication to improving international tax transparency. This move aims to offer greater tax certainty and clarity for multinational enterprises concerning their reporting duties.

The decision outlines the filing obligations for multinational enterprises operating in the UAE under the Top-Up Tax regime. It supports the consistent application of the Pillar Two Global Anti-Base Erosion (GloBE) Rules established by the OECD/G20 Inclusive Framework. Specifically, it mandates that each Constituent Entity, excluding any Investment Entity, located in the UAE; each Joint Venture and JV Subsidiary in the UAE; and each Stateless Constituent Entity classified as a Reverse Hybrid Entity under UAE law, must file a Pillar Two Information Return with the Federal Tax Authority.

Additionally, the decision allows these returns to be submitted either directly by the relevant entities or by a Designated Local Entity acting on their behalf. The Ministerial Decision is set to apply to fiscal years commencing on or after January 1, 2025.