UAE CbCR (Cabinet Resolution 44/2020) applies to UAE-parented MNE groups with consolidated annual group revenue ≥ AED 3.15 billion (~EUR 750 million) in the year before the reporting year. Filing deadline: 12 months after the financial year end. The Ministry of Finance exchanges CbCR data with 100+ jurisdictions under the OECD framework. UAE entities in foreign MNE groups must file a CbCR Notification.
Who must file UAE CbCR
Two types of obligation under UAE CbCR regulations:
- CbCR filing obligation: The UAE-resident Ultimate Parent Entity (UPE) of an MNE group whose consolidated group revenue in the preceding financial year was AED 3.15 billion or more must file a CbCR with the UAE Ministry of Finance within 12 months of the financial year end.
- CbCR Notification obligation: Every UAE-resident entity that is part of an MNE group (regardless of the group’s size) must file a CbCR Notification with the MoF within 12 months of the financial year end. The notification identifies the entity’s role in the group (UPE, Surrogate Parent, or constituent entity) and where the CbCR is filed.
- Surrogate Parent filing: Where the UPE is resident in a jurisdiction without a CbCR framework, a UAE entity in the group may be required to file the CbCR as a Surrogate Parent Entity (SPE) on behalf of the group.
What a UAE CbCR contains
- Table 1 — Jurisdiction-by-jurisdiction overview: Revenue (related/unrelated party), profit before tax, tax paid, tax accrued, employees, and stated capital for each jurisdiction where the group operates.
- Table 2 — Entity list: All constituent entities in each jurisdiction, their main business activities, and whether they are tax-resident.
- Table 3 — Additional information: Any additional information the MNE considers relevant to understanding Table 1 and 2.
The MoF exchanges UAE CbCR data under the Multilateral Convention on the Exchange of Country-by-Country Reports. This means that tax authorities in jurisdictions where the group has operations will receive the full Table 1 and 2 data — including profit per jurisdiction and effective tax rates. Groups with profit concentration in low-tax jurisdictions should understand how this data will be interpreted by the receiving tax authorities.
UAE CbCR penalties
- Late or non-filing of CbCR: Administrative penalties under Cabinet Resolution 44/2020 — up to AED 1 million for persistent non-filing.
- Late CbCR Notification: Administrative penalties — AED 50,000–100,000 for late notification.
- Incorrect information: Submitting incorrect CbCR data with intent to mislead is treated as a serious compliance failure — potential criminal referral.
Is your UAE entity part of a multinational group?
We prepare UAE CbCR and CbCR Notifications for UAE-headquartered groups and UAE entities in foreign MNE groups. Fixed fee.
Frequently asked questions
What is the UAE CbCR revenue threshold?
AED 3.15 billion in consolidated group revenue in the fiscal year preceding the reporting year. This is equivalent to approximately EUR 750 million — the OECD standard threshold. Groups below this level do not need to file a CbCR, but all UAE entities in any MNE group must still file a CbCR Notification.
What is a CbCR Notification in UAE?
A mandatory annual filing by every UAE-resident constituent entity of an MNE group, informing the Ministry of Finance: (1) which entity is filing the CbCR for the group, (2) whether it is filed in UAE or another jurisdiction, and (3) the filing entity’s role (UPE, SPE, or constituent). Filed via the MoF CbCR portal within 12 months of the financial year end.
Does a UAE subsidiary of a foreign parent need to file a CbCR?
It depends. If the foreign parent files a CbCR in a jurisdiction with which the UAE has a competent authority agreement for exchange, the UAE subsidiary only needs to file a CbCR Notification (not the full CbCR). If no exchange agreement exists, the UAE entity may need to file a Surrogate Parent CbCR in UAE.
How does UAE CbCR interact with Corporate Tax?
CbCR is a separate obligation from the CT return. However, the FTA can use CbCR data to inform transfer pricing risk assessment and to cross-check the CT return. Groups filing CbCR should ensure their TP documentation and CbCR are consistent — discrepancies attract scrutiny.