Group-level transparency for the largest UAE-headquartered groups

Country-by-Country Reporting requires large multinational groups to report, for each jurisdiction in which they operate, their revenues, profits, taxes paid and indicators of economic activity. In the UAE, under Cabinet Resolution No. 44 of 2020, the obligation applies where a UAE-resident Ultimate Parent Entity heads an MNE group whose consolidated revenue equalled or exceeded AED 3.15 billion in the preceding financial year. It gives effect to the BEPS Action 13 minimum standard the UAE adopted on joining the OECD Inclusive Framework.

For an in-scope group, the UAE-resident Ultimate Parent Entity must submit a CbCR notification to the Ministry of Finance on or before the last day of the group's Reporting Fiscal Year, confirming that it is the Reporting Entity for the group.

The same Ultimate Parent Entity must submit the Country-by-Country Report within 12 months after the end of the group's Reporting Fiscal Year. The report provides jurisdiction-by-jurisdiction aggregated information on the group's income, taxes and economic activity, used primarily for high-level transfer-pricing and BEPS risk assessment; it is not required to reconcile with the Master File or Local File.

Our approach

  • We assess whether the group falls within the UAE CbCR scope and thresholds.
  • We support the notification and the preparation of the Country-by-Country report.
  • We check consistency between the CbCR, the Master File and the wider documentation.
  • We help the group meet its UAE notification and filing deadlines.

The UAE position

  • Applies to — A UAE-resident Ultimate Parent Entity of an MNE group at AED 3.15 billion consolidated revenue
  • Framework — Cabinet Resolution No. 44 of 2020; BEPS Action 13 minimum standard (OECD Inclusive Framework)