Corporate tax
The global minimum tax now has a UAE filing list
The Ministry of Finance issued Ministerial Decision No. 133 of 2026 on 26 August. It sits under Cabinet Decision No. 142 of 2024 and answers a question the top-up tax framework had left open since it came into force: who, exactly, hands the paperwork to the Federal Tax Authority.
The answer is three categories. Every constituent entity located in the UAE, investment entities aside. Every joint venture and JV subsidiary located in the UAE. And every stateless constituent entity that is a reverse hybrid formed under UAE law. Each of them must submit a Pillar Two Information Return, or have a Designated Local Entity submit it on their behalf. The rules bite for financial years starting on or after 01 January 2025.
Two things are worth separating here, because they get confused constantly. The scope test is a group test: it catches multinational groups with consolidated revenue of EUR 750 million or more in two of the four preceding financial years. The filing obligation is an entity test, and it lands on the UAE entity regardless of how small that entity is. A three-person UAE subsidiary of a qualifying group is in scope. A standalone UAE company doing AED 40 million of revenue is not.
- EUR 750m Group consolidated revenue in two of four preceding years that brings the framework into play
- 01 Jan 2025 Financial years starting on or after this date fall inside the filing rules
Why it matters
The top-up tax runs on its own track. It has its own registration on EmaraTax, its own return and its own timetable, separate from the corporate tax return due nine months after year end. For a group with a 31 December 2025 year end, the first top-up tax filing falls under an 18-month transitional window rather than the standard 15 months. Groups that assume one tax registration covers both tracks tend to discover the gap late.
- Group subsidiaries
- Joint ventures
- Finance leads
Most of the companies we set up will never touch this, and it is worth saying so plainly rather than letting a headline about global minimum tax do its usual work on founders' nerves. The clients who should read the decision twice are the ones whose UAE entity is a small node in a large foreign group. If your shareholder is a listed parent, a family office with international holdings, or a group you joined through a joint venture, ask the parent's tax team one question this month: has a Designated Local Entity been appointed for the UAE, and is it us. The answer takes an email and settles who owns the return.

