Country-by-Country Reporting (CbCR) is part of the OECD’s Base Erosion and Profit Shifting (BEPS) project — specifically Action 13 — which was designed to give tax authorities around the world unprecedented visibility into how large multinational enterprise (MNE) groups allocate income, taxes, and economic activity across jurisdictions.

The UAE formally implemented CbCR requirements through Cabinet Resolution No. 32 of 2019, making it one of the first Gulf states to adopt this global standard. If your business is part of a large MNE group, understanding these obligations is essential.

What is Country-by-Country Reporting?

A Country-by-Country Report (CbCR) is an annual information return that provides tax authorities with a jurisdiction-by-jurisdiction breakdown of a multinational group’s:

  • Revenue (split between related-party and third-party sources).
  • Profit before income tax.
  • Income tax paid and accrued.
  • Number of employees.
  • Tangible assets (excluding cash and cash equivalents).
  • Stated capital and accumulated earnings.
  • Main business activities of each entity in each jurisdiction.

The report covers every jurisdiction where the MNE group has a presence, allowing tax authorities to identify potential mismatches between where profits are reported and where genuine economic activity occurs.

Who Must File a CbCR in the UAE?

The CbCR obligation in the UAE applies to Reporting Entities that meet the following conditions:

1. Revenue Threshold

The MNE group’s consolidated annual revenue must equal or exceed AED 3.15 billion (approximately USD 857 million) in the fiscal year preceding the reporting year.

This threshold aligns with the OECD’s recommended EUR 750 million threshold and places the obligation squarely on large multinationals — it does not apply to the vast majority of SMEs.

2. UAE Parent Entity

The obligation to file the CbCR in the UAE applies to the Ultimate Parent Entity (UPE) of the MNE group, if the UPE is tax resident in the UAE.

If the UPE is located outside the UAE, a Surrogate Parent Entity in the UAE (if designated by the group) may file instead. Alternatively, constituent entities in the UAE may be required to file a local notification and may have a secondary filing obligation if the UPE’s jurisdiction does not exchange CbCR data with the UAE.

3. UAE Constituent Entity Notification

Even if the CbCR itself is filed by the UPE abroad (in another BEPS-compliant jurisdiction), each UAE constituent entity of the MNE group must file an annual CbCR Notification with the UAE Ministry of Finance (MoF), confirming:

  • The identity and jurisdiction of the Reporting Entity (UPE or Surrogate Parent).
  • Whether the CbCR will be filed in the UAE or in another jurisdiction.

This notification obligation applies to all UAE constituent entities of qualifying MNE groups, regardless of whether the group is filing the CbCR in the UAE or overseas.

Filing Deadlines

  • CbCR Notification: Must be filed annually with the UAE Ministry of Finance within 4 months of the end of the MNE group’s fiscal year.
  • CbCR Filing (where the UAE entity is the Reporting Entity): Must be filed within 12 months of the end of the fiscal year to which the report relates.

For example, for a group with a 31 December 2024 fiscal year end:

  • Notification deadline: 30 April 2025.
  • CbCR filing deadline (if UAE is the filing jurisdiction): 31 December 2025.

How to File: The UAE Ministry of Finance Portal

Both the CbCR Notification and the CbCR itself are filed electronically through the UAE Ministry of Finance’s online portal (mof.gov.ae). Filers must register on the portal and submit reports in the OECD-specified XML schema format.

Automatic Exchange of Information (AEOI)

The UAE participates in the OECD’s automatic exchange framework for CbCRs. This means that the UAE tax authority (now the FTA) shares CbCR data received from MNE groups with the tax authorities of other participating jurisdictions where the group has operations. Reciprocally, the UAE receives CbCR data filed in other countries for groups with UAE constituents.

This exchange is governed by Competent Authority Agreements (CAAs) between the UAE and its exchange partners, and is subject to strict confidentiality rules.

CbCR and Transfer Pricing: How They Interact

CbCR is one of three tiers in the OECD’s transfer pricing documentation framework:

  • Country-by-Country Report: High-level, group-wide data by jurisdiction.
  • Master File: Group-wide narrative on business model, value chain, and TP policies.
  • Local File: Transaction-specific transfer pricing analysis for each jurisdiction.

The CbCR is used by tax authorities as a risk assessment tool — a prompt to identify jurisdictions where the group’s profit allocation appears inconsistent with economic substance, and where deeper scrutiny (using the Master File and Local File) may be warranted.

Penalties for Non-Compliance

Failure to comply with UAE CbCR obligations can result in:

  • Administrative penalties for late notification or late/incorrect filing.
  • Increased transfer pricing scrutiny from the FTA, as non-compliance creates a red flag.
  • Reputational risk with international tax authorities if the AEOI process reveals non-compliance.

Key Takeaways for UAE MNE Groups

  1. Check the threshold: Does your group’s consolidated revenue exceed AED 3.15 billion? If yes, CbCR obligations apply.
  2. Identify your Reporting Entity: Determine whether the UPE, Surrogate Parent, or a UAE constituent entity will file the CbCR.
  3. File the annual notification: Every UAE constituent entity in a qualifying MNE group must file the annual notification with the UAE Ministry of Finance, even if the CbCR itself is filed abroad.
  4. Prepare accurate group data: The CbCR requires precise, jurisdiction-by-jurisdiction financial and headcount data — this requires coordination across the group.
  5. Align with your transfer pricing documentation: CbCR should be consistent with your Master File and Local File positions.

How Success Business Advisors Can Help

Navigating CbCR obligations requires coordination between your UAE operations, your global finance team, and potentially multiple tax advisors across jurisdictions. At Success Business Advisors, we assist UAE MNE groups with:

  • Assessing whether CbCR obligations apply to your UAE entities.
  • Preparing and filing annual CbCR notifications with the UAE Ministry of Finance.
  • Coordinating CbCR data preparation for UAE filing obligations.
  • Aligning CbCR positions with your UAE transfer pricing documentation.

Contact Success Business Advisors for expert guidance on CbCR and broader transfer pricing compliance in the UAE.