Insights
UAE introduces Pillar Two Information Return filing framework for multinational enterprises
The United Arab Emirates (UAE) has taken a further step in implementing the Organisation for Economic Co-operation and Development (OECD)'s 'Pillar Two' global minimum tax framework with the issuance of Ministerial Decision No. 133 of 2026 (the Decision). While the Decision does not introduce any new tax liabilities, it provides important practical guidance on who must file the Pillar Two Information Return (PTIR) under the UAE's Domestic Minimum Top-up Tax (DMTT) regime and when UAE entities may rely on filings made elsewhere within their company group. For multinational enterprise (MNE) groups operating in the UAE, this represents an important development in the evolving Pillar Two compliance landscape.
