Country-by-Country Reporting (CbCR) in UAE

Ultimate Parent Entity

The top company of the group, normally responsible for preparing and filing the full report.

Surrogate Parent Entity

A group company appointed to file the report in place of the ultimate parent.

Other Constituent Entity

A UAE member of the group that must still notify the authorities and may need to file in certain situations.

1. Scoping and Applicability Review

Before any numbers are gathered, we establish exactly where you stand. We look at:

• How the group is owned and organised
• Whether consolidated revenue meets the AED 3.15 billion mark
• Which UAE entity carries the filing or notification duty
• Applicable due dates and submission formats
• The financial and operational data you’ll need to collect

2. Preparing the Country-by-Country Report

We build the report in the prescribed format, capturing for each jurisdiction:

• Revenue from related and unrelated parties
• Profit or loss before tax
• Income tax paid on a cash basis
• Current-year income tax accrued
• Headcount
• Tangible assets (excluding cash)
• Stated capital and accumulated earnings
• Every constituent entity and the main activities it carries out

3. Notification Filing

Every in-scope UAE entity must tell the authorities who will file for the group. We draft and review notifications covering:

• Details of the UAE reporting entity
• Group name and ultimate parent information
• The reporting financial year
• The identity and location of the filing entity
• Submission steps and timing

4. Data Checks and Quality Control

Errors in CbCR data can draw unwanted attention from tax authorities. Our review includes:

• Reconciling figures to source financial records
• Checking consistency with the consolidated financial statements
• Testing each jurisdiction’s data for completeness and logic
• Flagging gaps or inconsistencies before submission

The Master File

This gives a big-picture view of the whole group — how it is structured, how it makes money and how it prices dealings between group companies. It typically sets out:

• The group’s legal and ownership chart
• Key value drivers and main lines of business
• Important intangibles such as patents, trademarks and know-how
• How intra-group funding is arranged
• The group’s overall transfer pricing policies
• Consolidated financial and tax positions

The Local File

This zooms in on the UAE entity and shows that its dealings with related parties are priced as independent businesses would price them. It usually contains:

• An overview of the UAE entity and its management
• A breakdown of each related-party transaction
• Copies or summaries of intra-group agreements
• The pricing method chosen and the reasons for it
• Comparable data and benchmarking results
• Financials linking the transactions to the entity’s accounts

Is Your Business Required to Keep Them?

Whether these files are mandatory depends on your circumstances, including:

• The type and size of your related-party dealings
• Your UAE Corporate Tax position
• The documentation thresholds set by the authorities
• How your business is structured and what it does

A short review of these points will tell you whether preparing the files is an obligation or simply good practice.