TRANSFER PRICING & CbCR
MNE COMPLIANCE
Country-by-Country Reporting (CbCR) in UAE
We help groups based in or operating through UAE handle this obligation from start to finish. Our team confirms whether the rules apply, collects and checks the figures, prepares the report and notification, and works alongside your head office tax function so every UAE deadline is met without last-minute pressure.
Does Your Business Fall Within the UAE CbCR Rules?
The rules are triggered by group size. A UAE entity is generally in scope when it belongs to a multinational group whose consolidated revenue reached AED 3.15 billion (roughly EUR 750 million) or more in the financial year before the one being reported.
Once a group crosses that line, the UAE entity’s role within the group decides what it has to do:
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.
How We Support Your CbCR Compliance
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
Master File and Local File: The Wider Transfer Pricing Picture
CbCR is one part of a three-tier documentation framework. Alongside it, many UAE businesses must also keep a Master File and a Local File under the UAE’s transfer pricing rules.
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.
Why Businesses Work With Us
We offer a single point of contact for every part of your reporting cycle:
- ✓ Applicability reviews for UAE CbCR
- ✓ Group revenue threshold testing
- ✓ End-to-end CbC Report preparation
- ✓ Notification drafting and filing support
- ✓ Master File and Local File preparation
- ✓ Review of existing transfer pricing documentation
- ✓ Deadline tracking and compliance calendars
Frequently Asked Questions
Q1What does a CbCR reporting service in UAE cover?
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Q2What revenue level brings a group into the UAE CbCR rules?
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Q3Does every company in the UAE have to file a CbC Report?
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Q4What data goes into a Country-by-Country Report?
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Q5How is a Master File different from a Local File?
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Q6How do I know if my company needs a Master File and Local File?
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Related Tax & International Compliance Services in UAE
Meet Your UAE CbCR & Transfer Pricing Deadlines
Discuss your multinational group structure, CbCR notification requirements, or transfer pricing files with NUFCA chartered accountants today.