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The Ministry of Finance issues Ministerial Decision on requirements for filing Pillar Two Information Return, the Emirates News Agency reported. The decision specifies which entities must submit the return to the Federal Tax Authority along with the applicable conditions and procedures. It mandates use of the standard template issued by the OECD/G20 Inclusive Framework on July 17, 2023.
According to the associated Cabinet Decision, multinational enterprise groups with global consolidated revenue of 750 million euros or more fall within the scope of these rules. The Pillar Two Information Return requires detailed identification of all constituent entities, their tax identification numbers where available, locations and status under the rules. Additional disclosures cover the group’s overall corporate structure and data necessary to compute the effective tax rate and any top-up tax liability.
The filing deadline stands at 15 months after the end of the reporting fiscal year, with an extension to 18 months for the initial transition year, the decision states. This timeline allows groups sufficient opportunity to compile information from operations across multiple countries. The Federal Tax Authority retains flexibility to modify the requirements to remain consistent with updates to the Pillar Two Implementation Framework.
A KPMG assessment published in April 2025 found that the UAE has applied OECD commentary and administrative guidance on a retroactive basis from January 1, 2025.[[1]](https://kpmg.com/us/en/taxnewsflash/news/2025/04/uae-retroactive-implementation-oecd-pillar-two-guidance.html) This includes consolidated commentary from April 2024 and various packages of guidance released through January 2025. The UAE has opted to implement a qualified domestic minimum top-up tax while deferring the income inclusion and undertaxed payments rules for the time being.
OECD figures place the number of jurisdictions committed to the two-pillar solution at more than 140. The framework seeks to establish a minimum 15 percent effective tax rate on large multinational groups. In the UAE, the rules apply to fiscal years beginning on or after January 1, 2025.
Tax professionals have highlighted the need for robust data collection systems to meet the new reporting standards. The decision forms part of the country’s broader alignment with international tax norms following the introduction of federal corporate tax in 2023. Groups operating in the UAE must determine their filing obligations and prepare supporting documentation accordingly.
