What changed?
The UAE Top-up Tax framework was already in place, but the filing population and local-versus-foreign information-return mechanics required a dedicated implementing decision.
Ministerial Decision No. 133 of 2026 specifies which UAE-linked entities must file the Pillar Two Information Return and when a qualifying foreign filing can satisfy the UAE requirement, subject to local notification.
Practical consequence: Groups should map the UAE filing population, decide whether to use a Designated Local Entity and validate any reliance on a foreign filing and the related UAE notification obligation.
Confirmed facts
The UAE Ministry of Finance announced Ministerial Decision No. 133 of 2026 on 25 August 2026.
The Decision concerns the entities required to file the Pillar Two Information Return for the purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
The Decision applies to Fiscal Years starting on or after 1 January 2025.
What changed
The Decision identifies the UAE-linked entities that must file a Pillar Two Information Return with the Federal Tax Authority, including each UAE-located Constituent Entity other than an Investment Entity, each UAE-located Joint Venture and JV Subsidiary, and certain Stateless Constituent Entities that are Reverse Hybrid Entities created under UAE law.
The return may be filed directly by the relevant entity or by a Designated Local Entity on its behalf.
A local filing can be avoided where the required information return is filed by the Ultimate Parent Entity or a Designated Filing Entity in a jurisdiction that has a Qualifying Competent Authority Agreement in effect with the UAE for the relevant Reporting Fiscal Year, subject to the UAE notification requirements.