UAE country-by-country reporting 2026: CbCR requirements for multinationals.

CbCR reporting in the UAE applies to UAE-parented multinational groups whose consolidated group revenue is AED 3.15 billion or more in the year before the reporting year. The UAE parent files the Country-by-Country Report with the Ministry of Finance within 12 months of the financial year end. Every UAE-resident entity in a multinational group must also file a CbCR Notification, whatever the group’s size.

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.

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.

Master File, Local File and CbCR: how they differ

The three documents describe the same group at different levels of detail, and they do not replace each other.

• Master File: a group-wide overview. It sets out the group’s organisation, its main business drivers, its intangibles, its financing arrangements and its overall financial and tax position.
• Local File: a country-level transfer pricing record. It covers the controlled transactions of one entity, such as intra-group services, goods and loans, and shows how each was priced on an arm’s length basis.
• CbCR: a jurisdiction-level data report. It gives revenue, profit, tax and headcount by country and lists the group’s entities, which is the Table 1 to Table 3 content covered above.

In practice, the Master File explains the group, the Local File explains one entity’s pricing, and the CbCR gives tax authorities the figures to compare across countries. Whether a group must prepare a Master File or Local File depends on the rules set by the FTA, so check current FTA guidance before deciding which documents apply.

Common CbCR compliance mistakes in the UAE

Most CbCR problems come from the data work done before filing, not from the filing itself.

• Testing the threshold on the wrong figure. The test uses consolidated revenue for the preceding financial year, not the revenue of the UAE entity or the current year.
• Building Table 1 from individual ledgers instead of the consolidated financial statements, so jurisdiction totals do not reconcile to the group accounts.
• Leaving out a jurisdiction where the group has employees or a small presence but little revenue, so Table 1 looks incomplete.
• Using different exchange rates for revenue and profit in different tables, which makes the report look inconsistent to the receiving authority.
• Missing a change during the year, such as a new subsidiary, an acquisition or a closed entity, which changes the entity list in Table 2.

Each of these can be caught with a reconciliation step before filing. Keep a working file that ties every figure in the CbCR back to a source document and a dated sign-off.