Ministerial Decision No. 133 of 2026 on the Entities Required to File the Pillar Two Information Return for the Purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises

Minister of State for Financial Affairs:

• Having reviewed the Constitution,
• Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
• Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments,
• Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,
• Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises,

Has decided:

Article (1) - Definitions

The definitions set out in the Annexure to Cabinet Decision No. 142 of 2024 referred to above shall apply to this Decision.

Article (2) - Entities Required to File the Pillar Two Information Return

1. Subject to Clauses 2 and 3 of this Article, the following entities shall file a Pillar Two Information Return conforming to the requirements of Article 15 of the Annexure to Cabinet Decision No. 142 of 2024 referred to above with the Federal Tax Authority: (a) each Constituent Entity...