【CbCR change】Tax Reporting Requirements for Multinationals in UAE

Cabinet Resolution No. 32 on Country-by-Country Reporting was issued in UAE and requires the entities that are tax resident in the UAE and are part of a multinational group, to report to the Ministry of Finance.


It is focused on international business groups consist of Subsidiaries, affiliates, and branches in different tax jurisdictions, seeking to take advantage of grey tax regimes.

Applicability of Resolution: Multinational groups with consolidated revenues of at least AED 3.15 billion (approximately USD 855 million) per annum and wherein,

• An entity established in the UAE (being the parent company of a Multinational Group)
• An affiliate, through ownership or control (Subsidiaries, branches and Associate entities), of a Multinational Group in UAE,
  1. Whose parent company is not required to file a tax report in its jurisdiction of tax residency; or
  2. where such jurisdiction repeatedly fails to share tax information with UAE authorities
  3. It has elected to file the tax report in UAE

Reporting Requirements:

• CbCR Notification

Notification must be submitted, on or before the last day* of the group’s financial year by:

–      Any tax resident affiliated entity shall notify the UAE Ministry of Finance (MoF), whether it has the status of the parent entity (Ultimate or Surrogated)

–      Entities which are not Parent entity (Ultimate or Surrogated) shall notify the (MoF) with the details of Multinational Group entity submitting the CbCR and its tax residence.

*       Where financial reporting year of the Multinational group starting on 1st January 2019, the due date of first notifications must be on or before than 31 December 2019

• CbCR Filing

The filing must be done within 12 months from the end of group financial year* by: –      Parent Company being Tax Resident in UAE –      Affiliated Entity (being tax resident) if applicability conditions are met. *    Where financial reporting year of the Multinational group starting on 1st January 2019, the due date of first CbCR filing must be done latest by December 31st 2020. CbC Report The CbCR rules are in line with the guidance issued by the Organization for Economic Cooperation and Development (OECD) on the content and format of CbC reports Penalties How MBG can Help

• Assessment of availability of records to produce CbC Report
• Assist in aggregating the data required under the CbC Reporting
• Assist in compliances
• Advisory services