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Country-by-country reporting in the UAE is a transparency rule for large multinational groups. It comes from the UAE’s commitment to the OECD’s BEPS project. In short, the biggest groups must report key financial and tax data for every country where they operate. So this guide explains who must comply, the deadlines, what the report contains, and how it links to transfer pricing.
What Is Country-by-Country Reporting?
CbCR gives tax authorities a country-by-country view of a group’s revenue, profit, tax, and activity. It is the top tier of transfer pricing documentation under BEPS Action 13. It sits above the Master File and Local File. In the UAE, Cabinet Resolution No. 44 of 2020 governs it.
Who Must Comply?
The rule targets the largest groups. It applies when the ultimate parent is a UAE tax resident and the group’s consolidated revenue was AED 3.15 billion or more in the prior year. Groups below that level do not file a CbC report here. However, other transfer pricing documents may still apply.
Two Obligations: Notification and Report
In-scope groups face two duties.
- CbC Notification. First, you notify the authority of the reporting entity. This is generally due by the last day of the reporting year.
- CbC Report. Then you file the full report within twelve months of the year end.
Both go to the UAE competent authority through the official portal.
What the Report Contains
For each country, the report shows aggregate figures. These include revenues, profit before tax, tax paid and accrued, capital, retained earnings, employee numbers, and tangible assets. It also lists the group entities in each country and their main activities. As a result, authorities can spot transfer pricing and profit-shifting risk.
CbCR and Transfer Pricing Documentation
CbCR is the top of a three-part structure. The Master File describes the group’s global business and policies. The Local File covers the UAE entity’s related-party deals. Because corporate tax now includes formal transfer pricing rules, you should treat all three as one package. Our specialists cover the full range of country-by-country reporting and transfer pricing work.
Penalties for Non-Compliance
Missing a deadline, or filing wrong data, triggers administrative penalties. Moreover, CbCR data is shared with tax authorities worldwide. So accuracy and timing really matter.
Common Pitfalls in Country-by-Country Reporting in the UAE
Several mistakes catch out groups that are new to country-by-country reporting in the UAE. First, many miss the notification deadline, because it falls earlier than the report. Next, some misjudge which entity is the ultimate parent, or its tax residency. Then there is data inconsistency, where the country figures do not match the group accounts or the Master File. Finally, late or inaccurate filing is common. Because the data is exchanged across borders, one error can trigger scrutiny in several countries at once. Therefore, accuracy is essential.
How Parker Russell UAE Helps
First, we check whether you meet the AED 3.15 billion threshold. Then we prepare and file the notification and the report. We also align them with the Master File and Local File. In addition, we connect CbCR with your wider corporate tax compliance, so your position stays consistent.
Conclusion
Country-by-country reporting in the UAE is a high-stakes duty for the largest groups. It needs accurate, country-level data and strict deadlines. So treat CbCR as part of one transfer pricing and corporate tax strategy, not a standalone filing. That is the surest way to stay audit-ready.
FAQ
What is the CbCR threshold?
It applies to groups with a UAE parent and consolidated revenue of AED 3.15 billion or more in the prior year.
When are the filings due?
The notification is generally due by the last day of the reporting year, and the report within twelve months of the year end.
How does CbCR relate to transfer pricing?
It is the top tier of BEPS Action 13, above the Master File and Local File.
What if we are below the threshold?
You do not file a CbC report here, but other transfer pricing documents may still apply.
Need Support With CbCR Compliance?
Parker Russell UAE prepares CbCR notifications and reports and aligns them with your transfer pricing documents. Call +971 4 2959958 (Dubai) or +971 2 645 2666 (Abu Dhabi), email infodubai@pr-uae.com, or explore our CbCR services.
