UAE Pillar Two Information Return: Who Must File?

Each in-scope UAE constituent entity - excluding an Investment Entity - plus each in-scope UAE joint venture, JV subsidiary and specified stateless reverse hybrid is required to file a Pillar Two Information Return unless the obligation is discharged through an authorised UAE Designated Local Entity or a qualifying foreign filing by the group's UPE or Designated Filing Entity. A foreign filing does not remove the UAE notification requirement.

Key takeaways

Ministerial Decision No. 133 of 2026 applies to fiscal years beginning on or after 1 January 2025.
The default is entity-level filing, but a UAE Designated Local Entity can submit one return for represented UAE entities.
A conforming return filed overseas by the UPE or Designated Filing Entity can discharge UAE filing only when an effective Qualifying Competent Authority Agreement exists for that reporting year.
The UAE entities must still notify the FTA of the identity and location of the foreign filer.
Article 15.4 provides a 15-month P2IR deadline. For FY2025 ending 31 December 2025, the date is 31 March 2027 - before the 30 June 2027 first Top-up Tax Return deadline.

What is the UAE Pillar Two Information Return?

The Pillar Two Information Return (P2IR) is the UAE term for the standardised OECD GloBE Information Return. It provides the FTA with group, entity, jurisdictional and calculation data needed to evaluate Pillar Two outcomes. It is an information return; it is not the UAE Top-up Tax Return used to report and settle the domestic top-up tax liability.

The UAE Ministry of Finance announcement carried by Emirates News Agency confirms that Ministerial Decision No. 133 of 2026 applies to fiscal years starting on or after 1 January 2025 and identifies the UAE entities that must file or may use a Designated Local Entity.

The current interpretive basis is Ministerial Decision No. 96 of 2026, which applies from fiscal years beginning on or after 1 January 2025, adopts the OECD 2026 consolidated commentary and administrative guidance, and repeals Ministerial Decision No. 88 of 2025. It also adopts the OECD GloBE Information Return published in January 2025. See the official decision.

Who must file the P2IR in the UAE?

Ministerial Decision No. 133 of 2026 identifies the following default filers for an in-scope MNE group:

Each constituent entity located in the UAE, excluding an Investment Entity.
Each joint venture and JV subsidiary located in the UAE.
Each stateless constituent entity that is a Reverse Hybrid Entity created under UAE law.

This list should be applied after a technical entity-classification exercise. The Corporate Tax registration population and the consolidated legal-entity list are starting points, not a substitute for identifying Pillar Two constituent entities, permanent establishments, joint venture groups, flow-through entities and reverse hybrids.

Important exclusion
Investment Entities are expressly excluded from the UAE P2IR filing requirement in Ministerial Decision No. 133 of 2026. Their classification and results may still matter elsewhere in the Pillar Two analysis, so the conclusion should be documented rather than assumed.

What are the four filing routes?

Route	Who files?	Effect on UAE entity-level filing
1. Entity-by-entity	Each UAE constituent entity, UAE JV/JV subsidiary and specified stateless reverse hybrid.	Each filer submits its own P2IR.
2. UAE Designated Local Entity	One UAE constituent entity appointed and authorised by represented UAE entities.	A single UAE P2IR discharges the represented entities' filing obligations.
3. Foreign UPE	The UPE files in a jurisdiction with an effective Qualifying Competent Authority Agreement with the UAE.	Local P2IR filing can be discharged; UAE notification remains required.
4. Foreign Designated Filing Entity	A group-appointed DFE files in a qualifying exchange jurisdiction.	Local P2IR filing can be discharged; UAE notification remains required.

The exchange-agreement condition must be tested for the relevant reporting fiscal year. It is not enough that the filer's jurisdiction has generally committed to Pillar Two or has signed a multilateral instrument; the agreement must be effective with the UAE for the required exchange.

What should a UAE finance team map before choosing a filing route?

The local workstream should cover every UAE company, branch, permanent establishment, JV and relevant reverse hybrid - not only entities with a standalone UAE Corporate Tax return. Groups with operations across Dubai, Abu Dhabi and other emirates should build one controlled UAE Pillar Two population and then identify any category that the legislation requires to be computed or reported separately.

Legal name, trade licence, emirate or Free Zone, tax registration number and financial year for each UAE entity.
Pillar Two classification and the link to the UPE consolidation perimeter.
Whether the entity will file directly, appoint a UAE Designated Local Entity or rely on a qualifying foreign filing.
The owner of FTA communications, EmaraTax access, sign-off evidence and contingency filing.

What must be notified when the P2IR is filed overseas?

Where a qualifying UPE or Designated Filing Entity files outside the UAE, each affected UAE entity - or a Designated Local Entity acting for them - must notify the FTA of the identity of the filer and the jurisdiction in which that filer is located. The notification is a continuing UAE compliance step, not a one-time assumption embedded in the group's global filing plan.

Confirm the exact legal name, tax identification number and location of the foreign filer.
Retain evidence of the appointment where the filer is a Designated Filing Entity.
Confirm an effective Qualifying Competent Authority Agreement for the reporting fiscal year.
Create a contingency plan if the foreign return is rejected, delayed or not exchanged successfully.

When is the UAE Pillar Two Information Return due?

Article 15.4 of the UAE QDMTT legislation sets the P2IR and related notification deadline at no later than 15 months after the last day of the reporting fiscal year. This timeline should be calendared separately from registration and the Top-up Tax Return.

Milestone	Rule	FY2025 ending 31 Dec 2025
Top-up Tax registration	Transitional deadline where the first in-scope year ended before 30 April 2026.	30 November 2026
P2IR or foreign-filer notification	15 months after the last day of the reporting fiscal year.	31 March 2027
First Top-up Tax Return and payment	18 months after year-end for the first transition year.	30 June 2027

Do not import the 18-month extension into the P2IR deadline
The 18-month rule in Article 8.1.2 applies to the first Top-up Tax Return. The P2IR has its own 15-month deadline under Article 15.4. For a calendar-year group, the information return or notification is therefore due three months before the first UAE Top-up Tax Return.

What information does the P2IR contain?

The P2IR follows the OECD standardised structure. The exact submission format and technical validations should be confirmed against the FTA process available for the reporting year, but the underlying data typically includes:

MNE group identity, UPE details, group structure and constituent-entity classifications.
Jurisdictional allocation data, including permanent establishments, joint ventures and special entity categories.
Pillar Two Income or Loss and Adjusted Covered Taxes by relevant entity and jurisdiction.
Jurisdictional ETR, SBIE, excess profit, top-up tax percentage and top-up tax calculations.
Safe-harbour positions, elections, transition rules and allocation of top-up tax under applicable charging rules.
Explanatory data needed to reconcile the return to consolidated and local financial information.

The return is not a narrative tax memo. It is a structured data product. A strong filing process therefore combines technical tax analysis with controlled data lineage, validation rules and accountable sign-off. The OECD GloBE Information Return is the baseline reference.

Designated Local Entity and DDFE: similar names, different jobs

Term	P2IR role	Registration / tax-return role
Designated Local Entity (DLE)	Files a single P2IR or notification for authorised UAE entities.	No automatic responsibility for the Top-up Tax Return or payment.
Domestic Designated Filing Entity (DDFE)	May also be appointed as the DLE if properly authorised.	Registers represented domestic group members; files the Top-up Tax Return and pays top-up tax for that domestic group.
Designated Filing Entity (DFE)	A group entity, often outside the UAE, appointed to file the global P2IR/GIR.	Its foreign filing can discharge UAE P2IR filing only if the exchange-agreement condition is met.

The FTA's August 2026 Scope and Registration Guide confirms that the DLE role is different from the DDFE role. One UAE entity can hold both appointments, or the group can separate them. The choice should follow capability, access to global data, governance and payment authority - not convenience of naming.

How should a group build a filing-ready P2IR process?

Map the filing population and decide which of the four filing routes applies to each UAE entity.
Confirm the UPE/DFE filing jurisdiction and exchange-agreement position for the relevant year.
Appoint and authorise the DLE and DDFE, if used, with clear responsibility matrices.
Create a data dictionary linking every P2IR field to its source system, owner, transformation and reviewer.
Reconcile the entity-level dataset to the consolidation package, UAE Corporate Tax returns, transfer-pricing records and the final ETR model.
Run technical and logical validations early: entity identifiers, currencies, dates, elections, duplicate records and jurisdiction totals.
Complete a dry run before the filing window and preserve evidence of review, approvals and foreign-filing reliance.

Common P2IR mistakes to avoid

Treating the P2IR and Top-up Tax Return as the same filing.
Assuming that a foreign GIR automatically removes the UAE notification requirement.
Confusing a Designated Local Entity with a Domestic Designated Filing Entity.
Using the Corporate Tax entity list without testing Pillar Two entity classifications.
Waiting for final global calculations before identifying missing UAE source data.
Relying on manual spreadsheet overrides without version control or documented review.
Calendaring 30 June 2027 for every first-year obligation and missing the 31 March 2027 P2IR deadline.

For the wider regime, read SBC's UAE Pillar Two DMTT guide and registration guide.

Frequently asked questions

Is the P2IR the same as the UAE Top-up Tax Return?

No. The P2IR is the standardised information return under Article 15. The Top-up Tax Return is the UAE tax return used to report the domestic top-up tax liability, and payment is due with that return.

Can a UAE Designated Local Entity file one return for all UAE entities?

Yes, if the relevant UAE entities appoint and authorise it. The filing discharges the represented entities' separate P2IR obligations, subject to the scope of the appointment.

Does an overseas filing remove every UAE obligation?

No. A qualifying UPE or DFE filing can discharge local P2IR filing, but the UAE entities or their DLE must still notify the FTA of the filer's identity and location.

What if there is no effective exchange agreement with the UAE?

The foreign-filing relief is unavailable for that reporting year. The group must use a local UAE filing route unless another valid route applies.

Do Investment Entities file a UAE P2IR?

No. Ministerial Decision No. 133 of 2026 excludes Investment Entities from the identified filing requirement. The entity's classification and other Pillar Two consequences should still be documented.

What is the FY2025 calendar-year P2IR deadline?

31 March 2027. That is 15 months after 31 December 2025 and is earlier than the 30 June 2027 first Top-up Tax Return deadline.

Does each Dubai or Abu Dhabi entity have to file its own P2IR?

Entity-level filing is the default for in-scope UAE entities, regardless of emirate. However, an authorised UAE Designated Local Entity may file for represented entities, and a qualifying foreign UPE or DFE filing may discharge local filing when the exchange conditions are met. UAE notification can still be required.

Primary sources and further reading

How SBC Tax Consulting can help

SBC's international tax team can support filing-route design, data readiness and return review. We test the entity population against the Ministerial Decision No. 133 of 2026 categories, confirm whether a foreign filing genuinely discharges the local obligation, prepare the FTA notification, and build the data lineage that keeps the P2IR reconciled to your ETR model and corporate tax filings. Contact SBC before the 15-month window closes.

This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.