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Country by Country Reporting

On 30 April 2019, the Cabinet Resolution No. 32 of 2019 was issued introducing the requirements on Country-by-Country Reporting (CbCR) in the United Arab Emirates.

CbC Reporting is part of Action 13 of the Base Erosion and Profit Shifting (BEPS) initiative led by the Organization for Economic Co-operation and Development (OECD) and the Group of Twenty (G20) industrialized nations.

BEPS Action 13 requires large Multinational Groups of Entities (MNEs) to file a CbC Report that should provide a breakdown of the Multinational Group’s global revenue, profit before tax, income tax accrued and some other indicators of economic activities for each jurisdiction in which the MNE operates.

The purpose of CbC Reporting is to eliminate any gap in information between the taxpayers and tax administrations with regards to information on where the economic value is generated within the MNE Group and whether it matches where profits are allocated and taxes are paid on a global level.

According to the Resolution, CbCR requirements are applicable to ‘financial reporting years’ starting on or after January 1st 2019. Accordingly, for the financial reporting year starting on January 1st 2019, the CbC report must be submitted latest by December 31st 2020.


Frequently Asked Questions

A. General CbC reporting considerations

1. What is CbC Reporting?

CbC Reporting is part of Action 13 of the Base Erosion and Profit Shifting (BEPS) initiative led by the Organization for Economic Co-operation and Development (OECD) and the Group of Twenty (G20) industrialized nations. BEPS Action 13 requires large Multinational Groups of Entities (MNEs) to file a CbC Report that should provide a breakdown of the Multinational Group’s global revenue, profit before tax, income tax accrued and some other indicators of economic activities for each jurisdiction in which the MNE operates. The purpose of CbC Reporting is to eliminate any gap in information between the taxpayers and tax administrations with regards to information on where the economic value is generated within the MNE Group and whether it matches where profits are allocated and taxes are paid on a global level.

2. What is the UAE Legislation governing CbC Reporting?

The UAE legislation governing CbC Reporting is covered by the UAE’s Cabinet Resolution no. 32 of 2019.

3. Can the OECD guidance on CbC Reporting be used to interpret the UAE CbC Reporting Legislation?

The OECD guidance on the implementation of CbC Reporting can be used to interpret the UAE CbC Reporting legislation to ensure a consistent and standard approach to CbC Reporting across all implementing countries. It should be noted that there are some differences between the OECD Model legislation and the UAE CbC Reporting Legislation. Where there is a conflict, the UAE CbC Reporting legislation takes precedence.

4. How should terms contained in the UAE CbC Reporting Legislation and these FAQs be interpreted?

A number of terms used in these FAQs are defined in the UAE CbC Reporting Legislation, including, e.g. “country-by-country report”. Whilst these FAQs provide further information to assist with the interpretation of some of these terms, the reader is referred to the UAE CbC Reporting Legislation for a full definition of all relevant terms.

5. How will the MoF safeguard the confidentiality of information provided in CbC Reports?

The UAE Ministry of Finance (the Competent Authority, abbreviated as MoF) will ensure the confidentiality of the information contained in CbC Reports provided to it, in accordance with the provisions of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MCAA) developed by the OECD and the Council of Europe.

6. What will the information provided on a CbC Report be used for?

The BEPS Action 13 Report sets out three permitted uses for information contained in CbC Reports, namely:

  • To assess high-level transfer pricing risk;
  • To assess other BEPS-related risks; and
  • For economic and statistical analysis.

The UAE is committed to using information provided in CbC Reports in accordance with the permitted uses above. The MoF will not use CbC Reporting data beyond such limitations.

7. What information should be kept by a CbC Reporting Entity i.e. the entity required to file the CbC Report in the UAE? For what duration?

The effective records should be kept by a CbC Reporting Entity for 5 years following the date on which the CbC Report is submitted to the MoF. The aforementioned records may be kept electronically, provided that the records are retained in a readable electronic format and in accordance with UAE laws and regulations relating to the retention of electronic records.


Page last updated : 16/10/2019 8:51 AM