What are the new UAE Pillar Two reporting rules in 2026?

UAE Ministerial Decision No. 133 of 2026 clarifies which entities are responsible for filing the Pillar Two Information Return under the UAE Top-up Tax framework established by Cabinet Decision No. 142 of 2024.

Which multinational companies are subject to UAE Pillar Two?

The UAE Top-up Tax framework generally applies to Constituent Entities of multinational enterprise groups with consolidated annual revenue of EUR 750 million or more in at least two of the four fiscal years immediately preceding the relevant fiscal year, subject to the detailed rules and exclusions.

Who must file the UAE Pillar Two Information Return?

Relevant UAE Constituent Entities, certain Joint Ventures and JV Subsidiaries, and specified Reverse Hybrid Entities may be required to file, unless the obligation is validly discharged through a Designated Local Entity, Ultimate Parent Entity or Designated Filing Entity under the applicable rules.

What is the deadline for the UAE Pillar Two Information Return?

The Pillar Two Information Return and relevant notifications are generally due within 15 months after the end of the Reporting Fiscal Year.

What is the UAE Top-up Tax registration deadline in 2026?

For a relevant fiscal year ending before 30 April 2026, the Federal Tax Authority guidance states that the Top-up Tax registration application should generally be submitted by 30 November 2026. Other first-year cases are generally subject to a seven-month registration period from the end of the first fiscal year in which the entity falls within scope.

What is the penalty for late Top-up Tax registration in the UAE?

The Federal Tax Authority guidance provides for an AED 10,000 administrative penalty where a required Top-up Tax registration application is not submitted within the applicable deadline.

Are UAE free zone companies exempt from Pillar Two?

No blanket Pillar Two exemption applies merely because a company operates in a UAE free zone. A free zone entity belonging to an in-scope multinational enterprise group should separately assess its position under the UAE Domestic Minimum Top-up Tax rules.

Is the Pillar Two Information Return the same as the UAE Corporate Tax Return?

No. The Pillar Two Information Return is a separate reporting requirement under the global minimum tax framework and should not be confused with the normal UAE Corporate Tax Return or the separate Top-up Tax Return.