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Who is responsible for Pillar Two reporting when a multinational group has several UAE entities?
This question is becoming increasingly important as the UAE implements its Domestic Minimum Top-up Tax (DMTT) under Pillar Two. For groups operating through multiple UAE subsidiaries, simply knowing the tax rate is not enough. Finance teams need a clear DMTT reporting calendar UAE that identifies deadlines, data owners, reporting entities and the responsibilities of the parent company.
The UAE DMTT generally applies to UAE Constituent Entities that are members of MNE groups meeting the €750 million global revenue threshold in at least two of the four preceding financial years. The regime applies to financial years beginning on or after 1 January 2025.
So, how should a multinational group organise its UAE DMTT reporting process? Let us break the responsibilities and timeline down step by step.

The UAE Domestic Minimum Top-up Tax is part of the global OECD/G20 Pillar Two framework. The DMTT is designed to apply a minimum effective tax framework to qualifying multinational enterprise groups. In the UAE, it applies to Constituent Entities belonging to MNE groups that meet the €750 million consolidated revenue threshold in at least two of the four financial years immediately preceding the relevant year.
The UAE DMTT applies for financial years beginning on or after 1 January 2025.
This means that multinational groups with UAE operations need to consider DMTT as a separate compliance workstream rather than treating it as simply another part of their ordinary UAE Corporate Tax filing.
A UAE subsidiary may be only one entity within a much larger multinational group, but its financial and tax data can form part of the group’s Pillar Two calculations. The parent company or designated reporting team may therefore need information from each UAE entity covering areas such as:
The exact information required depends on the group’s reporting structure and the applicable Pillar Two rules.
This is why a DMTT group reporting calendar should allocate responsibilities at entity level rather than simply assigning the entire task to the group tax department.
A major development for UAE businesses came on 25 August 2026, when the Ministry of Finance issued Ministerial Decision No. 133 of 2026.
The decision specifies the entities required to file the Pillar Two Information Return with the Federal Tax Authority. According to the Ministry of Finance, these include:
The decision also allows the Pillar Two Information Return to be filed directly by the relevant entity or by a Designated Local Entity on its behalf. It applies to Fiscal Years beginning on or after 1 January 2025.
Businesses should refer directly to Ministerial Decision No. 133 of 2026 when determining which UAE entities are required to file. The UAE Ministry of Finance’s official Financial Legislation database provides the decision and downloadable legislation.
Official source: UAE Ministry of Finance – Financial Legislation
This is preferable to relying solely on third-party summaries because the decision itself is the authoritative source for the filing entities.
The UAE’s Cabinet Decision No. 142 of 2024 provides the core filing timeline for the Top-up Tax Return. Under Article 8.1.2, the Top-up Tax Return must generally be filed no later than 15 months after the last day of the Reporting Fiscal Year.
For the first Transition Year of any Constituent Entity of the MNE Group, the deadline is extended to 18 months after the last day of the Reporting Fiscal Year.
Example: Assume a UAE MNE group has a Reporting Fiscal Year ending on 31 December.
For a normal reporting year:
For the first Transition Year:
The transition rule is important because groups entering the UAE DMTT framework for the first time may have additional time for their initial reporting cycle.
The exact filing provision is contained in Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises.
Official FTA PDF: Cabinet Decision No. 142 of 2024 – Top-up Tax on MNEs
Businesses should use the legislation itself when confirming the applicable reporting period and transition-year treatment.
A practical calendar should begin well before the statutory filing date. For example, a group with a 31 December financial year-end could structure its internal reporting process as follows:
| Period | Key activity | Main responsibility |
| January | Confirm reporting entities and group structure | Parent / Group Tax |
| February–March | Collect UAE entity financial data | UAE subsidiaries |
| April–May | Review tax and accounting adjustments | Group Tax / Finance |
| June–July | Review Pillar Two calculations | Group Tax |
| August | Identify missing information and resolve discrepancies | UAE entities + Parent |
| September–October | Management review and technical review | Group Tax |
| November | Finalise reporting package | Parent / Designated Local Entity |
| December | Filing readiness and documentation | Filing entity |
| Statutory deadline | Submit required return/information | Responsible filing entity |
The exact internal timetable should be adapted to the group’s reporting year and the applicable statutory requirements.
The key principle is simple:
Do not make the legal filing deadline the date on which data collection begins.

A UAE subsidiary’s role is usually focused on providing accurate and timely local information. The parent or central tax team may request:
A reporting calendar should therefore include a monthly or quarterly data submission process, rather than waiting until the annual filing period.
The parent company or central tax function typically coordinates the group-wide Pillar Two process. Its responsibilities may include:
The parent company should also establish clear deadlines for each subsidiary.
For example:
This creates a buffer before the statutory deadline.
The UAE rules allow the Pillar Two Information Return to be filed by a Designated Local Entity on behalf of relevant UAE entities. Ministerial Decision No. 133 of 2026 specifically confirms that the Pillar Two Information Return may be submitted either directly by the relevant Constituent Entity, Joint Venture or JV Subsidiary, or by the Designated Local Entity on its behalf.
This can be particularly useful for multinational groups with several UAE entities.
Instead of each UAE company independently managing the reporting process, the group may establish a coordinated local filing structure.
However, centralisation does not eliminate the responsibility of individual UAE entities to provide complete and accurate information to the designated reporting team.
Another important point is that DMTT and UAE Corporate Tax should not be placed into one generic tax deadline without distinction. They are separate compliance frameworks. A UAE company may therefore need to maintain:
This can include:
This can include:
Keeping the two calendars separate reduces the risk of confusing different deadlines or assigning the wrong responsibility to a local finance team.
A practical calendar should contain five layers.
Maintain a list of all UAE Constituent Entities, Joint Ventures, and other relevant entities.
Assign a responsible person for each information category.
For example:
| Information | Suggested owner |
| Financial statements | UAE Finance |
| Tax data | UAE Tax / Finance |
| Payroll | HR / Payroll |
| Fixed assets | Finance |
| Group structure | Legal / Group Tax |
| Pillar Two calculations | Group Tax |
| Final filing | Designated filing entity |
Set deadlines weeks or months before the statutory deadline.
Include technical, accounting, and management review stages.
Maintain copies of submitted information, calculations, supporting schedules and relevant correspondence.
This creates an audit trail and makes future reporting periods easier to manage.
Because the UAE DMTT framework is evolving, businesses should rely on current government legislation and guidance.
The Ministry of Finance provides an official overview of the UAE DMTT, including the scope of the regime and the €750 million MNE revenue threshold.
Official resource: UAE Ministry of Finance – Domestic Minimum Top-up Tax
This is the directly relevant government decision for determining which entities are required to file the Pillar Two Information Return. It applies to Fiscal Years beginning on or after 1 January 2025.
Official announcement: Ministry of Finance – Pillar Two Information Return Requirements
This is the key legislation for the UAE Top-up Tax framework and contains the 15-month general filing deadline and 18-month first-transition-year deadline for the Top-up Tax Return.
Official legislation: FTA – Cabinet Decision No. 142 of 2024
The Ministry’s legislation database is useful for checking later amendments and additional Pillar Two decisions. As of August 2026, it lists both Ministerial Decision No. 133 of 2026 and Ministerial Decision No. 96 of 2026 concerning the Pillar Two framework.
Official legislation database: UAE Ministry of Finance – Financial Legislation
For UAE subsidiaries and groups, DMTT reporting often requires close coordination between bookkeeping, financial reporting, tax data, and group-level requirements. Ripple Accountant can support UAE businesses with accounting and financial reporting processes that help keep the underlying data organized and ready for tax and group reporting. This can include maintaining accounting records, reconciling financial information, preparing management and financial reports, supporting tax-related data collection, and helping businesses establish structured reporting processes.
If your UAE business is part of an international group and you need help organising financial data or preparing for DMTT and Pillar Two reporting, contact Ripple Accountant to discuss your requirements and build a reporting process suited to your group structure.
The UAE Domestic Minimum Top-up Tax is the UAE’s implementation of a domestic minimum tax under the OECD/G20 Pillar Two framework. It generally applies to UAE Constituent Entities belonging to qualifying MNE groups meeting the €750 million revenue threshold in at least two of the four preceding financial years.
The UAE DMTT applies to financial years beginning on or after 1 January 2025.
Under Cabinet Decision No. 142 of 2024, the Top-up Tax Return is generally due within 15 months after the last day of the Reporting Fiscal Year. For the first Transition Year of any Constituent Entity of the MNE Group, the period is generally 18 months.
Not necessarily. Ministerial Decision No. 133 of 2026 permits the Pillar Two Information Return to be filed directly by the relevant entity or by a Designated Local Entity on its behalf, subject to the applicable rules.
The subsidiary should establish a clear internal process for providing the financial, tax, payroll, asset, and structural information requested by the group reporting team. Internal deadlines should be set well before the group’s final filing deadline.
A reliable DMTT reporting calendar UAE should connect the responsibilities of the parent company, UAE subsidiaries, and any designated local filing entity. The UAE DMTT framework applies to qualifying MNE groups from financial years beginning on or after 1 January 2025, while the 2026 Ministerial Decision No. 133 provides greater clarity on which UAE entities must file the Pillar Two Information Return. For multinational groups, Pillar Two compliance should be treated as an ongoing reporting process, not a task that starts immediately before the statutory deadline.
Disclaimer: This article is provided for general informational purposes only and does not constitute tax, accounting, or legal advice. UAE DMTT, Pillar Two, reporting and filing requirements may change through legislation, ministerial decisions, FTA guidance, or other official publications. Businesses should review the latest legislation and guidance issued by the UAE Ministry of Finance and Federal Tax Authority and obtain professional advice before making compliance decisions.
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