United Arab Emirates imposes 3 separate filing obligations under Pillar Two. The earliest is Pillar Two Information Return, due Not stated in the Ministerial Decision — unconfirmed. Checked against the authority on 3 October 2026.
Domestic top-up tax only — the UAE has expressly decided not to implement an IIR.
Top-up Tax registration
The FTA published a Top-up Tax Guide on scope and registration dated 26 August 2026. Registration deadlines and channel could not be confirmed from a government source reachable here.
| Charge | Local name | In force from |
|---|---|---|
| IIR | Not adopted — express policy decision | n/a |
| UTPR | Not adopted | n/a |
| Domestic | Domestic Minimum Top-up Tax (DMTT) | Financial years starting on or after 1 Jan 2025 |
Also: PTIR · GIR
The UAE's GloBE information return.
Ministerial Decision No. 133 of 2026 on the Pillar Two Information Return ↗
Notification of the identity and location of the entity filing the PTIR.
Ministerial Decision No. 133 of 2026 on the Pillar Two Information Return ↗
The return on which Top-up Tax is reported and paid.
No Top-up Tax penalty instrument could be located on a government source. Deliberately not stated.
3 separate obligations: Pillar Two Information Return; Notification of foreign filing; Top-up Tax Return.
Not stated in the Ministerial Decision — unconfirmed. Filed by: Each constituent entity located in the UAE excluding investment entities; each JV and JV subsidiary; each stateless reverse hybrid created under UAE law. A designated local entity may file for the others.. Channel: Unconfirmed.
Not stated — unconfirmed. Filed by: Each entity under Article 2(1) of MD 133/2026, or the designated local entity. Channel: Unconfirmed.
Top-up Tax registration. The FTA published a Top-up Tax Guide on scope and registration dated 26 August 2026. Registration deadlines and channel could not be confirmed from a government source reachable here.
No Top-up Tax penalty instrument could be located on a government source. Deliberately not stated.
Every row on this page was checked against the authority's own published page on 3 October 2026. Adoption and the IIR decision are verified against the Ministry of Finance. Filing deadlines and channels are NOT published in the reachable instruments and are marked unconfirmed.
Saurabh Satija, “United Arab Emirates Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-united-arab-emirates, accessed [date].
Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.
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