UAE Ministry of finance issues decision on requirements for filing pillar two information returns

The Decision constitutes a clarification of filing obligations and procedures rather than a substantive amendment to the UAE’s Top-Up Tax liability rules. In-scope groups should treat it as an immediate priority by mapping UAE constituent entities, joint ventures, JV subsidiaries and reverse hybrid entities against the three filing categories and determining at an early stage whether to file individually or nominate a single Designated Local Entity.

Groups electing a Designated Local Entity should establish clear internal protocols covering data collection, sign-off and record retention well in advance of the filing deadline, recognising that GloBE data will ordinarily be sourced centrally before localisation. Businesses should continue to monitor the FTA for procedural guidance on format, portal and timeline, and should track this Decision together with the related registration, deregistration and due-diligence decisions already issued under the Top-Up Tax regime.