UAE: Amendments to country-by-country reporting requirements

UAE: Amendments to CbC reporting requirements

Cabinet Resolution No. 44 of 2020 amends Cabinet Resolution No. 32 of 2019 on country-by-country (CbC) reporting in the United Arab Emirates.


The CbC reporting requirements were introduced in 2019, and included rules for the submission of CbC reports by multinational enterprises (MNEs). Read TaxNewsFlash

Cabinet Resolution No. 44 of 2020 supersedes the 2019 resolution, and amends the definition of “reporting entity” to specify that the ultimate parent entity of an MNE group (tax resident in the UAE) is the only entity of the MNE group required to comply with CbC reporting obligations. Accordingly, with regard to:

  • CbC notification: Each ultimate parent entity of an MNE group (tax resident in the UAE) is required to notify the competent authority that it is the entity responsible for filing the CbC report. The 2019 resolution had a broader scope for this notification, whereby all constituent entities of an MNE group (tax resident in the UAE) were required to comply with such notification. As such, only the ultimate parent entity is now required to file the notification. As under the 2019 resolution, the notification must be submitted no later than the last day of the group's reporting fiscal year.
  • CbC report: Each reporting entity (ultimate parent entity) of an MNE group (tax resident in the UAE) must file the CbC report in the UAE within 12 months following the last day of the reporting fiscal year of the MNE group. All provisions in respect of the surrogate parent entity in the 2019 resolution have been removed (repealed).

Certain provisions from the 2019 resolution have not changed. For instance, provisions pertaining to applicable threshold, penalties, timelines, and information required under CbC reporting are consistent with the rules under the 2019 resolution.

What's next?

Guidance is still pending concerning:

  • The CbC report completion and submission process. The online portal and guidance are expected to be released in coming months.
  • The automatic exchange process for exchanging CbC reports with other jurisdictions.

Read an August 2020 report prepared by the KPMG member firm in the UAE

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