Country-by-Country Reporting UAE: The AED 3.15 Billion Threshold Explained

Short answer: UAE country-by-country reporting applies only where a Multinational Enterprises Group has total consolidated revenue of AED 3,150,000,000 or more in the fiscal year immediately before the reporting year, and the group’s Ultimate Parent Entity is UAE tax resident. Everyone else files nothing.

Country-by-country reporting is one of those pieces of UAE tax compliance that generates far more anxiety than it should, and almost always in the wrong businesses. A founder in Dubai reads that the UAE has a CbCR reporting regime, sees the acronyms and the international-tax vocabulary, and quietly assumes it is one more filing to stack alongside the VAT return and the Corporate Tax return.

In reality, CbCR is a large-group transparency measure with a threshold set in the billions of dirhams, and Cabinet Resolution No. 44 of 2020 draws the line clearly enough that most UAE businesses can settle the question in an afternoon. This guide sets out exactly what the AED 3.15 billion threshold tests, who the obligation attaches to, what the report discloses, what happens to a UAE subsidiary of a foreign parent, and which far lower UAE thresholds you should be looking at instead.

What country-by-country reporting is for

CbCR came out of the OECD’s Base Erosion and Profit Shifting project — specifically BEPS Action 13 — as a response to a simple problem. Large multinational groups operate across dozens of jurisdictions, and for years tax authorities had no single comparable view of how a group’s global profit was distributed against where its people, assets and sales actually sat. A group could report the bulk of its profit in a low-tax jurisdiction that housed a handful of staff, while the jurisdictions with the factories, the customers and the workforce saw comparatively little. CbCR was designed to make that pattern visible in one standardised table.

The UAE adopted the framework in stages. Cabinet Decision No. 32 of 2019 came first; Cabinet Resolution No. 44 of 2020 replaced it on 4 June 2020 and is the instrument in force. Around the same period the UAE ratified the international plumbing that makes the exchange work — Federal Decree No. 48 of 2018 on the Multilateral Administrative Agreement for the Automatic Exchange of Information, Federal Decree No. 54 of 2018 on the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and Federal Decree No. 24 of 2019 on the Multilateral Agreement between Competent Authorities on the Exchange of Reports on a Country-by-Country Basis. That is why the UAE regime exists at all, and why its threshold mirrors the global one rather than being set to catch domestic businesses.

Article 5 of the Resolution is worth reading, because it tells you what the Ministry of Finance may and may not do with the report. The Ministry uses it to assess high-risk transfer pricing, to assess other base erosion and profit shifting risks in the State, to assess the risk of non-compliance by group members with transfer pricing rules, and for economic and statistical analysis. It expressly may not rely on the report when carrying out transfer pricing adjustments. CbCR is a risk lens, not an assessment.

AED 3,150,000,000

Total consolidated group revenue in the preceding fiscal year at or above which a Multinational Enterprises Group falls within scope of UAE country-by-country reporting under Cabinet Resolution No. 44 of 2020

The AED 3.15 billion threshold, exactly as written

The single most important fact about UAE CbCR is the threshold, because it decides everything else. Here is the rule as the Resolution states it, alongside the other scope-defining provisions, so you can check the wording rather than take a summary on trust.

What the rule fixes	The text, as written	Article	Last verified
Revenue threshold	”a total consolidated group revenue that is equal to or more than AED 3,150,000,000 … during the Fiscal Year immediately preceding the Reporting Fiscal Year as indicated in its Consolidated Financial Statements for that preceding Fiscal Year”	Art. 1, definition of MNE Group, Cabinet Resolution No. 44 of 2020	4 Aug 2026
Multinational test	A group including “two or more companies the tax residence of which is located in different jurisdictions”, or one company taxed on activity carried out through a permanent entity in another country	Art. 1, definition of MNE Group	4 Aug 2026
Who notifies	”Each Ultimate Parent Entity of the MNE Group whose tax residence is located in the State shall notify the Competent Authority that it is the Reporting Entity”	Art. 2(1)	4 Aug 2026
Competent Authority	”The Ministry of Finance”	Art. 1, definitions	4 Aug 2026
Report deadline	”no later than the twelve (12) months grace period subsequent to the last day of the Reporting Fiscal Year of the MNE Group”	Art. 4(1)	4 Aug 2026
Effective from	The reporting obligation “shall take effect on January 01, 2019”	Art. 4(2)	4 Aug 2026
What it replaced	Cabinet Resolution No. 32 of 2019 “shall be repealed”	Art. 12	4 Aug 2026
Date of issue	Shawwal 12, 1441 AH, corresponding to 4 June 2020	Signature block	4 Aug 2026

Three details in the threshold sentence do the heavy lifting, and each one trips someone up.

First, it is total consolidated group revenue, measured across the whole group using the consolidated financial statements, not the revenue of any single entity. A UAE company turning over AED 200 million in Jebel Ali is not close to the threshold on its own — but if it is one Constituent Company of a global group whose consolidated revenue reaches AED 3.15 billion, the group is in scope even though this one entity is small.

Second, it is the preceding fiscal year that matters. You test the prior year’s consolidated revenue to decide whether an obligation exists for the current reporting year. A group that crosses the line this year does not acquire a retrospective filing; it looks at whether last year’s consolidated figure met the threshold. The practical consequence is that scope for the current year is knowable on day one of that year, which is exactly why the notification can fall due by its last day.

Third, the definition only ever engages for a genuine multinational — a group with tax residence in more than one jurisdiction, or a single company taxed on a permanent entity abroad. A purely domestic UAE structure, however elaborate its internal arrangement of mainland and free zone entities, is not a Multinational Enterprises Group for this purpose and does not enter the regime at any revenue level.

Why the number is AED 3,150,000,000 and not a round figure

The threshold looks oddly precise because it is a translation, not a policy choice made in Abu Dhabi. The OECD BEPS Action 13 minimum standard sets the bar at EUR 750 million of consolidated group revenue, and participating jurisdictions express that in local currency. AED 3,150,000,000 is the UAE’s near-equivalent. It means a UAE-parented group is tested against the same commercial scale as a group parented in Germany, Singapore or Japan.

That has a practical consequence for currency. The UAE dirham is pegged to the US dollar at AED 3.6725, so a group that consolidates in dollars can convert with a fixed rate and reach a stable answer. A group consolidating in euros, sterling or rupees has no peg and has to pick a rate, apply it consistently and document the choice.

Group reporting currency	Equivalent of AED 3,150,000,000	Basis	Last verified
AED	AED 3,150,000,000	The figure as written in Cabinet Resolution No. 44 of 2020	4 Aug 2026
USD	≈ USD 857.7 million	AED 3.6725 per USD, the UAE Central Bank dirham peg	4 Aug 2026
EUR	The OECD standard is EUR 750 million; the dirham figure is the UAE’s local-currency expression of it	OECD BEPS Action 13	4 Aug 2026
Any other currency	No conversion method is specified — document the rate and date used and apply it consistently	Cabinet Resolution No. 44 of 2020 is silent on conversion	4 Aug 2026

The euro row deserves care. The Resolution does not say “EUR 750 million”; it says AED 3,150,000,000. If your group sits close to the line, test the dirham figure and keep the workings rather than reasoning from the euro number.

Who actually files, and the two-part test

Meeting the threshold is only half the analysis. Cabinet Resolution No. 44 of 2020 attaches the obligation to one entity: the Ultimate Parent Entity of the in-scope group, where that entity’s tax residence is located in the UAE.

The Resolution defines the Ultimate Parent Entity by two conditions. It owns, directly or indirectly, enough interest in one or more Constituent Companies that it is required to prepare consolidated financial statements under the accounting principles of its jurisdiction — or would be if its equity were publicly traded. And no other Constituent Company in the group owns that kind of interest in it. In plain terms, it is the company at the top that consolidates everyone else and answers to nobody above.

Group shape	Consolidated revenue in preceding fiscal year	UAE CbC notification?	UAE CbC Report?
Standalone UAE company, no foreign entities	Any amount	No	No
UAE mainland and UAE free zone entities under common UAE ownership, no foreign entity	Any amount	No	No
UAE-parented group with subsidiaries in Saudi Arabia and India	Below AED 3,150,000,000	No	No
UAE-parented group with subsidiaries in Saudi Arabia and India	AED 3,150,000,000 or more	Yes — Art. 2(1)	Yes — Art. 2(2) and Art. 4(1)
UAE subsidiary of a foreign-parented group	Below AED 3,150,000,000	No	No
UAE subsidiary of a foreign-parented group	AED 3,150,000,000 or more	No — Art. 2 binds only a UAE-resident UPE	No
UAE company with a permanent entity abroad, taxed there	AED 3,150,000,000 or more	Yes, if it is the Ultimate Parent Entity	Yes

Source for the obligation rows: Articles 2 and 4 of Cabinet Resolution No. 44 of 2020. Last verified 4 August 2026.

The sixth row saves UAE finance teams the most time and is the most widely misunderstood. Cabinet Resolution No. 44 of 2020 repealed Cabinet Resolution No. 32 of 2019 and, in doing so, dropped both the constituent-entity notification and the secondary and surrogate local-filing routes that the OECD model permits. Article 2 imposes the notification only on an Ultimate Parent Entity whose tax residence is in the State. So a Dubai subsidiary of a group headquartered in Mumbai, London or Riyadh has nothing to notify and nothing to file in the UAE — even where the parent’s jurisdiction does not exchange reports with the UAE. Many jurisdictions do impose a local filing in that situation. The UAE does not.

What the CbC Report actually discloses

Where a group is in scope, Article 3 sets out what goes in. The report gives tax authorities a structured, jurisdiction-by-jurisdiction view of the group’s economic footprint, and it follows the standard template in Annex III to Chapter V of the OECD Transfer Pricing Guidelines.

Data point required by Article 3(1)(a)	Reported for	Note
Revenue	Each country the group operates in	Aggregate, split between related and unrelated party amounts in the OECD template
Profits or losses before income tax	Each country	Aggregate for all Constituent Companies resident there
Income tax paid	Each country	Cash basis for the year
Income tax accrued	Each country	Current-year accrual
Stated capital	Each country	Aggregate
Accumulated earnings	Each country	Aggregate
Number of employees	Each country	Headcount, on a consistent basis year to year
Tangible assets other than cash and cash equivalents	Each country	Non-monetary assets
Identity of each Constituent Company	Each entity	Jurisdiction of tax residence, jurisdiction of establishment where different, and main business activities — Art. 3(1)(b)

Source: Article 3 of Cabinet Resolution No. 44 of 2020. Last verified 4 August 2026.

Set side by side, the financial table and the entity list let an authority see whether profit is being reported in jurisdictions that also show meaningful headcount, assets and third-party revenue — or whether profit is pooling somewhere the group has almost no real presence. That is the whole point of the exercise.

Worked UAE scoping examples in AED

Abstract thresholds are easy to misapply. Here are five scoping runs of the kind we work through with UAE clients, using the two tests in order: is this a Multinational Enterprises Group, and did consolidated revenue reach AED 3,150,000,000 in the preceding fiscal year.

Scenario	Structure	Preceding-year consolidated revenue	Conclusion
Dubai trading LLC with a DMCC sister company	Both UAE resident, common individual shareholder, no foreign entity	AED 410 million	Not an MNE Group — no CbCR at any revenue level
Abu Dhabi holding company with subsidiaries in Oman and Egypt	UAE-resident Ultimate Parent Entity	AED 1.9 billion	MNE Group, but below AED 3,150,000,000 — no notification, no report
Sharjah-parented manufacturing group with entities in India, Kenya and the UK	UAE-resident Ultimate Parent Entity	AED 3.4 billion	In scope — notify the Ministry of Finance by the last day of the reporting fiscal year, report within twelve months of its end
Free zone logistics company in JAFZA, sole UAE arm of a Singapore group	Foreign Ultimate Parent Entity	AED 6.2 billion group-wide	Nothing to file in the UAE — Art. 2 binds only a UAE-resident UPE
DIFC holding company with branches in Qatar and Bahrain taxed locally	UAE-resident Ultimate Parent Entity, permanent entities abroad	AED 3.05 billion, rising	Out of scope this year on the preceding-year figure; re-test next year and diarise the notification early

Illustrative structures and figures, applying Articles 1, 2 and 4 of Cabinet Resolution No. 44 of 2020. They are worked examples, not client facts.

The fifth row is the one that catches people. The threshold is tested on the preceding fiscal year, so a group crossing AED 3.15 billion in the current year knows during that year that it will be in scope for the next one. That is the moment to build the data pipeline, not eleven months later.

Where CbCR sits in the UAE transfer pricing stack — and the threshold that actually bites

CbCR is not a free-standing obligation dropped into UAE tax law. It is the top layer of a three-tier transfer pricing documentation model, and the layers underneath reach far more UAE businesses.

The CbC Report sits at the top, filed only by groups crossing AED 3,150,000,000 with a UAE-resident parent. Below it sits the master file, a high-level narrative of the group’s global business, its profit drivers, its supply chains, its intangibles and its transfer pricing policies. Below that sits the local file, an entity-specific analysis of the UAE taxpayer’s own related-party transactions tested against the arm’s-length standard.

Ministerial Decision No. 97 of 2023 sets the UAE trigger for the lower two, and it contains the figure most UAE groups should actually be checking.

Documentation tier	UAE trigger, as written	Instrument	Last verified
CbC Report and notification	MNE Group with total consolidated group revenue of “AED 3,150,000,000 … or more” in the preceding fiscal year, with a UAE-resident Ultimate Parent Entity	Arts. 1, 2 and 4, Cabinet Resolution No. 44 of 2020	4 Aug 2026
Master file and local file — multinational limb	Taxable Person is “a Constituent Company of a Multinational Enterprises Group … that has a total consolidated group Revenue of AED 3,150,000,000 … or more in the relevant Tax Period”	Art. 2(1)(a), Ministerial Decision No. 97 of 2023	4 Aug 2026
Master file and local file — standalone limb	”Where the Taxable Person’s Revenue in the relevant Tax Period is AED 200,000,000 … or more”	Art. 2(1)(b), same Decision	4 Aug 2026
Arm’s-length principle and TP documentation power	Transfer pricing rules and the authority to require documentation sit in the Corporate Tax Law itself	Federal Decree-Law No. 47 of 2022, Arts. 34 and 55	4 Aug 2026

Read the standalone limb again. A single UAE company with revenue of AED 200,000,000 in a Tax Period must maintain a master file and a local file, whether or not it is part of any multinational group and whether or not it has ever heard of CbCR reporting. That is roughly one sixteenth of the CbCR threshold. Groups that confirm they are nowhere near AED 3.15 billion and stop there are the ones we most often find with an unaddressed local file obligation.

Ministerial Decision No. 97 of 2023 also narrows what goes into the local file, which is a relief rather than a burden. Article 2(3) excludes transactions with UAE resident persons other than exempt persons, persons who have made an Article 21 election, and persons taxed at a different Corporate Tax rate. It also excludes transactions with a natural person, and with a juridical person related only by being a partner in an unincorporated partnership, provided the parties act as if independent — which Article 2(4) defines as transacting in the ordinary course of business and not exclusively or almost exclusively with each other.

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Being outside the AED 3.15 billion CbCR threshold is not a clean bill of health for transfer pricing. The master file and local file trigger at AED 200 million of a single company’s revenue — and the businesses most likely to miss that are the ones that relaxed the moment they cleared country-by-country reporting.

The other UAE thresholds worth checking in the same sitting

If you are opening the consolidated accounts anyway, test the numbers that genuinely apply to UAE businesses at ordinary scale. These are different regimes with different authorities, and none of them turns on CbCR.

Obligation	UAE threshold, as published	Primary source	Last verified
Corporate Tax rate	0% on Taxable Income up to AED 375,000; 9% on the excess	Federal Decree-Law No. 47 of 2022, Art. 3	4 Aug 2026
Corporate Tax return and payment	Within 9 months from the end of the relevant Tax Period	Federal Decree-Law No. 47 of 2022, Arts. 48 and 53	4 Aug 2026
Master file and local file	Consolidated group revenue AED 3,150,000,000+, or the person’s own revenue AED 200,000,000+	Ministerial Decision No. 97 of 2023, Art. 2(1)	4 Aug 2026
CbC Report and notification	Consolidated group revenue AED 3,150,000,000+ with a UAE-resident Ultimate Parent Entity	Cabinet Resolution No. 44 of 2020	4 Aug 2026
VAT registration, and the designated zones in the UAE question for goods traders	Mandatory above AED 375,000 of taxable supplies and imports; voluntary above AED 187,500	UAE Government portal — VAT	4 Aug 2026
CbCR record retention	Five years after the date the report was submitted	Cabinet Resolution No. 44 of 2020, Art. 7(1)	4 Aug 2026

The overlap in the middle two rows is the point. The AED 3,150,000,000 figure appears twice — once as the CbCR gate and once as the multinational limb of the documentation rules — but the AED 200,000,000 standalone limb has no CbCR counterpart, which is precisely why a UAE business can be out of one and squarely inside the other.

Deadlines and the compliance calendar for an in-scope UAE group

For the minority of UAE groups that do cross the line, the calendar is unusual because the two obligations sit almost a year apart. Take a group with a 31 December financial year that crossed AED 3,150,000,000 in 2025 and is therefore in scope for reporting fiscal year 2026.

Date	What falls due	Basis
Early 2026	Confirm 2025 consolidated revenue against AED 3,150,000,000 and document the conclusion	Art. 1, definition of MNE Group
Through 2026	Assemble jurisdiction-level revenue, profit, tax paid and accrued, headcount and tangible assets from every Constituent Company	Art. 3(1)
31 December 2026	CbC notification to the Ministry of Finance — “no later than the last day of the Group’s Reporting Fiscal Year”	Art. 2(1)
31 December 2027	CbC Report filed with the Ministry of Finance — within “twelve (12) months” after the last day of the reporting fiscal year	Art. 4(1)
Until 31 December 2032	Retain the underlying records — “a minimum period of five (5) years after the date of reporting”	Art. 7(1)

Dates derived from Cabinet Resolution No. 44 of 2020 applied to a 31 December year end. Last verified 4 August 2026. Confirm live dates with the UAE Ministry of Finance before relying on them.

The full mechanics of both filings, including the portal, the data-assembly failure modes and the penalty structure in detail, are set out in our guide to the CbC filing deadline UAE groups work to, and the distinction between the two documents is unpacked in CbC notification vs report.

What happens when a group gets it wrong

Penalties matter here mainly as a scale check. They tell you the Ministry treats this as a large-group obligation with large-group consequences, which is another reason not to volunteer into a regime you are outside.

Failure	Administrative penalty	Article
Reporting Entity misses the CbC Report deadline	AED 1,000,000, plus AED 10,000 for each day the failure continues, capped at AED 250,000	Art. 8(1)(a)
Ultimate Parent Entity misses the notification deadline	AED 1,000,000, plus AED 10,000 per day capped at AED 250,000	Art. 8(2)
Information reported incomplete or inaccurate	Minimum AED 50,000, maximum AED 500,000	Art. 8(1)(d)
Records not kept for five years	AED 100,000	Art. 8(1)(b)
Failure to provide information the Ministry requests	AED 100,000	Art. 8(1)(c)
Overall cap for any one reporting fiscal year	AED 1,000,000, excluding the daily additions above	Art. 8(3)

Source: Article 8 of Cabinet Resolution No. 44 of 2020. Last verified 4 August 2026.

Two procedural safeguards sit alongside the amounts and materially change how they play out. Article 9(2) requires the Ministry to notify the entity in writing and grant a grace period of fourteen business days to remedy the violation before applying a penalty. Article 9(3) removes liability where the entity satisfies the Ministry that it had a reasonable excuse — though Article 9(4) rules out two excuses expressly: insufficient funds, and the information being held by a third party. Article 10 then allows an appeal within thirty business days, which the Ministry must decide within sixty business days; if it does not respond in time, the appeal is deemed successful and the penalty is cancelled.

Why most UAE SMEs are out of scope, and how to prove it once

For the typical UAE SME the practical answer is no, and it is worth understanding why so the answer holds up under scrutiny rather than being a hopeful guess.

Start with the threshold. AED 3.15 billion in consolidated group revenue is an enormous number in the SME and mid-market context. A business in Deira, Business Bay or Mussafah would need to be part of a genuinely large multinational to approach it. Most UAE SMEs are two or three orders of magnitude below, so the revenue test alone resolves it.

Then add the structure test. CbCR only engages for a Multinational Enterprises Group with tax residence in more than one jurisdiction and an Ultimate Parent Entity that consolidates it. That definition is narrower than everyday usage. Plenty of impressive-looking companies in UAE free zones are subsidiaries of foreign parents, and it is the parent’s group, not the UAE arm, that carries any obligation — and under Article 2 that obligation does not fall in the UAE at all.

Put the two together and the vast majority of UAE businesses are outside on both counts. That is by design. The regime was never meant to reach the SME layer, and nothing in the UAE Corporate Tax reforms since 2023 has moved it down.

The scoping memo: what to write down and keep

The deliverable is a page, and its value is that it converts a vague assumption into something a Ministry of Finance query, an auditor or a buyer in a due diligence process can read in two minutes.

Section of the memo	What to record	Why it matters
Group structure	Every entity, its jurisdiction of tax residence, and its jurisdiction of establishment where different	Establishes whether an MNE Group exists at all under Art. 1
Ultimate Parent Entity	Which entity consolidates, and where it is tax resident	Art. 2 binds only a UAE-resident UPE
Revenue tested	The consolidated revenue figure, the fiscal year it relates to, and the statements it came from	The test is on the preceding fiscal year, not a forecast
Currency and rate	Reporting currency, conversion rate to AED, date and source of that rate	AED 3,150,000,000 is a dirham test
Conclusion	In scope or out of scope, with the article relied on	Makes the position auditable
Lower tiers checked	Whether Art. 2(1)(b) of Ministerial Decision No. 97 of 2023 applies at AED 200,000,000	This is where most UAE groups actually land
Review trigger	The revenue level and structural change that would require re-testing	Acquisitions and new foreign subsidiaries move the answer

Do this once a year, at the point the consolidated accounts are signed, and CbCR stops consuming attention. A business genuinely inside the threshold should take specialist advice, because the filing, the notification timing and the interaction with the group’s home-country obligations reward getting it right. For everyone else, a single documented scoping conclusion is the entire exercise.

Common UAE scoping errors, and what they actually cost

Error	What it looks like in practice	The cost
Testing one entity’s revenue instead of consolidated revenue	A UAE company with AED 900 million turnover assumes it is close to the threshold	Advisory hours spent on a regime it will never enter
Testing the current year instead of the preceding one	Group crosses AED 3.15 billion mid-year and panics about an immediate filing	Wrong deadline diarised; the real notification date is next year’s last day
Assuming a UAE subsidiary must notify	Foreign-parented group instructs its Dubai finance team to file locally	Wasted effort — Art. 2 imposes nothing on a constituent entity
Clearing CbCR and stopping	Group confirms it is below AED 3.15 billion and closes the file	Missed master file and local file obligation at AED 200,000,000 under Ministerial Decision No. 97 of 2023
Never re-testing after an acquisition	Structure changes; the memo from two years ago is still the answer	Scope can move in a single transaction
Filing with the FTA instead of the Ministry of Finance	Team assumes EmaraTax handles everything tax	The deadline keeps running while the group believes it has complied

What an in-scope UAE group has to build

If the scoping memo lands on “in scope”, the work that follows is a data exercise rather than a form-filling one, and it is worth being honest about its shape.

The Ministry of Finance can, under Article 6(2), require the Reporting Entity to produce information — including copies of records, books and other documents — within a period not exceeding fourteen business days. Article 7(1) then requires those records to be kept for five years after the report is filed, and Article 7(2) requires an English translation on request where records are held in another language. Article 7(4) closes the obvious loophole: an entity that enters an arrangement whose main purpose can reasonably be considered to be avoiding these obligations remains responsible as if it had not.

In practice that means the group needs a repeatable pipeline that pulls revenue split by related and unrelated party, profit before tax, tax paid on a cash basis, tax accrued, stated capital, accumulated earnings, headcount and tangible assets from every Constituent Company, on a consistent basis, reconciled back to the consolidated statements. UAE finance teams usually find the UAE data is the easy part. The friction comes from subsidiaries closing on different calendars, reporting in different functional currencies, and never having been asked for a tax-jurisdiction cut before.

Where this leaves your business

Country-by-country reporting is best understood by what it is not. It is not a routine annual filing for UAE businesses, it is not administered by the Federal Tax Authority, and it is not triggered by ordinary domestic growth in Dubai or anywhere else in the Emirates. It is a transparency instrument aimed at the largest multinational groups, engaged only when total consolidated group revenue reaches AED 3,150,000,000 in the preceding fiscal year and the group’s Ultimate Parent Entity is UAE tax resident. For most UAE SMEs the correct and defensible answer is a documented “out of scope”, reached once and filed away.

What deserves ongoing attention is the layer beneath. Transfer pricing documentation and related-party disclosures under Federal Decree-Law No. 47 of 2022 reach far more UAE businesses than CbCR ever will, and the AED 200,000,000 standalone trigger in Ministerial Decision No. 97 of 2023 is the number a growing UAE group should have on its dashboard. Handle the scoping properly and you spend your compliance effort where it actually belongs.

Pair a clean CbCR scoping conclusion with transfer pricing documentation support so the master file and local file obligations that sit below the threshold are identified and met, and with corporate tax services so related-party disclosures and the arm’s-length position are handled inside the annual return rather than discovered late. For groups that genuinely cross the line, our country-by-country reporting support covers the scoping test, the notification and the report preparation for filing with the Ministry of Finance.

Velmont Crest is a DED-licensed UAE accounting and advisory firm providing preparation and compliance support across the full Corporate Tax and transfer pricing documentation stack — from related-party disclosure and local file preparation through to CbCR scoping and reporting support — for mainland and free zone businesses across Dubai, Sharjah and Abu Dhabi. Read more on our insights hub or get in touch via our contact page for a quote.

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Disclaimer: Velmont Crest is a DED-licensed accounting and advisory firm providing preparation and compliance support services. We are not a law firm, the Ministry of Finance, the Federal Tax Authority, or an FTA-registered tax agent representing clients before the authorities. CbCR thresholds, filing routes and transfer pricing rules change and can turn on the specific facts of a group — verify current requirements with the UAE Ministry of Finance and consult a qualified professional for advice specific to your circumstances before acting.

References

• Cabinet Resolution No. 44 of 2020 on Organising Reports Submitted by Multinational Companies (PDF)
• Ministerial Decision No. 97 of 2023 on Transfer Pricing Documentation (PDF)
• UAE Ministry of Finance — Country-by-Country Reporting
• Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (PDF)
• OECD — Country-by-Country Reporting (BEPS Action 13)
• UAE Government Portal — Taxation