Country-by-Country Reporting: When UAE Groups Need to File

Country-by-Country Reporting (CbCR) is the OECD-driven disclosure regime for multinational groups. UAE-headquartered groups now have CbCR obligations once they cross the AED 3.15 billion consolidated revenue threshold.

Who is in scope

A UAE-resident Ultimate Parent Entity must file a CbCR if its group's consolidated revenue exceeds AED 3.15 billion in the financial year preceding the reporting year. The same threshold applies whether the group is purely UAE-domestic or international (CbCR was extended to UAE-only groups in 2024).

A UAE-resident subsidiary of a foreign group typically does not file directly, the parent's CbCR is shared with the FTA via the Multilateral Competent Authority Agreement. But UAE subsidiaries must file a Notification confirming who within the group files the CbCR.

What goes in the report

Three tables per country where the group operates: Table 1 (revenue from related and unrelated parties, profit before tax, tax accrued and paid, stated capital, retained earnings, employees, tangible assets); Table 2 (each entity, its country of residence, its main business activities); Table 3 (notes and explanations).

The data must be drawn from the group's consolidated financial accounts, with consistent definitions across countries. The FTA accepts data based on the parent's GAAP (IFRS, US GAAP, etc.), but consistency over time is essential.

Filing mechanics

CbCR is filed annually via EmaraTax, due 12 months after the end of the reporting period. The Notification (confirming who files for the group) is due by the end of the reporting period itself. Penalties for non-compliance are AED 1,000,000 for the parent's failure to file, plus AED 100,000 for each subsidiary's missed Notification.

Data is exchanged with treaty partners via the OECD Common Transmission System. So a UAE-headquartered group with operations in Germany, the UK and Singapore will see its CbCR data flow to the German, UK and Singaporean tax authorities automatically.

Practical implications

CbCR is descriptive, it does not change tax liabilities directly. But the reported numbers feed into transfer pricing risk assessments by tax authorities globally. A jurisdiction with high revenue, low profit, and few employees attracts scrutiny.

Most groups in scope use the same data feed for CbCR, BEPS Pillar Two, and MNE local filings. Build the CbCR data flow once and reuse it. Acowntant's enterprise module produces all three in one workflow for groups above threshold.

This guide is general information, not professional advice. For situations that involve specific facts, talk to your accountant, or hire one of ours from the marketplace.