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UAE clarifies Pillar 2 tax reporting requirements for multinationals

The changes are likely to prompt multinational groups to reassess regional tax planning and reporting. iStock.

03 Sep 2026, 10:12 am

The UAE has introduced new tax reporting requirements for multinational enterprises, in a significant step in the country’s alignment with international tax standards, experts have said.

The new rules, set out in Ministerial Resolution No. 133 of 2026, require certain multinational groups operating in the UAE to file a ‘Pillar 2’ information return. The reporting obligation forms part of the UAE’s adoption of the Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE) Rules, commonly known as Pillar 2, which are designed to ensure large multinational enterprises pay a minimum level of tax regardless of where they operate.

The requirements will apply to financial years beginning on or after 1 January 2025 and are intended to support the operation of the UAE’s top-up tax regime for multinational businesses. The Ministry of Finance said the measures reflect the country’s continued commitment to transparency and international compliance standards.

Under the resolution, filing obligations apply to UAE-based constituent entities within multinational groups, subject to certain exceptions for investment entities. Joint ventures and their subsidiaries may also be required to submit returns, alongside stateless constituent entities that are treated as reverse hybrid entities under applicable legislation.

The framework allows the return to be filed by a constituent entity, a joint venture or subsidiary, or an authorised local representative acting on behalf of the relevant group. The UAE government said the approach is intended to provide flexibility and align domestic reporting obligations with internationally recognised standards developed by the OECD and G20.

Penny Simmons, who specialises in tax risk management at Pinsent Masons, said: “It is interesting to see the UAE implementing Pillar 2 as it continues to develop its business tax framework. Businesses operating in the UAE should now review their tax governance, compliance processes and documentation practices by performing a gap analysis to ensure they can meet the new reporting obligations. The changes are also likely to prompt multinational groups to reassess aspects of their regional tax planning and reporting arrangements ahead of implementation.”