COUNTRY-BY-COUNTRY REPORTING UAE
Velmont Crest prepares Country-by-Country Reporting documentation for large multinational enterprise (MNE) groups in the UAE — the CbC notification due before the reporting fiscal year-end, the CbC report due within 12 months of it, and the per-jurisdiction data behind them, filed with the Ministry of Finance under Cabinet Decision No. 44 of 2020. This applies only to groups at or above AED 3.15 billion in consolidated revenue; most UAE SMEs are far below that and never need it. We prepare and coordinate the documentation; contentious tax opinions and formal representation go to a registered advisor.
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Overview
Country-by-Country Reporting (CbCR) is an OECD BEPS Action 13 measure, implemented in the UAE by Cabinet Decision No. 44 of 2020 and administered by the Ministry of Finance. It is the top tier of the OECD's three-tier transfer pricing documentation — Master File, Local File and CbC report — and it exists so tax authorities can see how a group's profit and tax are spread across jurisdictions. As the top tier of UAE multinational reporting, it applies only to the very largest groups.
The scope is narrow by design. CbCR applies to UAE-headquartered multinational enterprise (MNE) groups whose consolidated group revenue reaches AED 3.15 billion in the preceding financial year — or to a UAE entity that is the Ultimate Parent of such a group. That is a large-group threshold. The overwhelming majority of UAE SMEs are nowhere near it and have no CbC notification and no CbC report to file, full stop. So the honest first step is a threshold test, not a sales pitch.
For the groups that are in scope, there are two distinct obligations on two separate clocks. A CbC notification must be filed by each UAE constituent entity before the end of the group's reporting fiscal year, stating its status and identifying which entity and jurisdiction will file the report. A CbC report — the full jurisdiction-by-jurisdiction data return — is then due within 12 months of the fiscal year-end, filed in the UAE where a UAE entity is the Ultimate Parent or a Surrogate Parent. The report breaks the group down per jurisdiction: revenue (related and unrelated party), profit or loss before tax, income tax paid and accrued, stated capital, accumulated earnings, number of employees and tangible assets.
The part that keeps it advisory-clean: we prepare and coordinate the documentation — the notification, the report and the per-jurisdiction data assembly — and we align it to the group's Master File and Local File and to the audited group accounts. CbCR is administered by the Ministry of Finance; we support in-scope UAE members and parents with preparation and MoF-portal coordination. We don't act as a tax agent, we don't represent you before the authority, and we don't guarantee a particular outcome. Where a contentious position or formal representation is needed, we coordinate with a registered advisor and hand over a file that's ready to work from.
What you get
Four things an in-scope group stops having to worry about once the notification and report are built on the right cycle.
CbCR is a large-group obligation. Most businesses that ask about it turn out to be well below the AED 3.15 billion consolidated-revenue threshold and owe nothing at all. We test group revenue against the threshold before anything else, so an SME is told plainly it is out of scope, and a genuinely in-scope group knows exactly which filings it owes and where.
Every UAE constituent entity of an in-scope group must file a CbC notification before the end of the group's reporting fiscal year — even when the report is filed overseas by the parent. We identify the correct filing status, prepare the notification and submit it through the Ministry of Finance portal, so that obligation is closed off before the deadline rather than left open.
Where a UAE entity is the Ultimate Parent, a full CbC report is due within 12 months of the fiscal year-end. We assemble it to the OECD three-table format — the jurisdictional overview, the constituent-entity listing and the additional-information table — reconciled to the audited group accounts, so it reads as coherent evidence rather than a rushed data dump built under deadline.
CbCR is the top of the OECD's three-tier transfer pricing documentation. A CbC report that contradicts the Master File is a red flag to a reviewer. We prepare the report so it tells a consistent story across all three tiers and cross-reference the underlying figures, so a reviewer opening the file sees one coherent position, not three that argue with each other.
Compare scope
CbCR only engages at the AED 3.15 billion consolidated-revenue mark. Below it, there is nothing to file. Above it, what you owe depends on whether a UAE entity is merely a constituent entity relying on an overseas parent's report, or the Ultimate Parent that has to file the report here. We confirm which column you're actually in before preparing anything.
| Criteria | Below threshold | Notification only | Full CbC report most involved |
|---|---|---|---|
| Typically applies when | Group consolidated revenue below AED 3.15 billion | In-scope group; UAE entity is a constituent entity, parent files overseas | In-scope group; UAE entity is the Ultimate or Surrogate Parent |
| What's produced | Nothing — no CbC obligation at all | CbC notification, filed with the MoF | CbC notification + full CbC report |
| Per-jurisdiction data | Not required | Reported overseas by the parent entity | Full OECD three-table format, filed here |
| Notification deadline | Not applicable | Before the end of the reporting fiscal year | Before the end of the reporting fiscal year |
| Report deadline | Not applicable | Filed by the overseas parent — no UAE report | Within 12 months of the fiscal year-end |
| Link to TP documentation | TP disclosure form may still apply separately | Master File / Local File likely apply too | Top tier over Master File + Local File |
| Velmont's role | Confirm you're out of scope, in writing | Prepare & file the notification | Notification + report + group coordination |
| Best fit for | SMEs and mid-market groups — the vast majority | UAE members of large foreign-parented groups | UAE-headquartered large multinational groups |
Thresholds and obligations follow Cabinet Decision No. 44 of 2020 and the OECD BEPS Action 13 standard; CbCR is administered by the Ministry of Finance. Velmont Crest prepares and coordinates the notification and report and aligns them to the group's transfer pricing documentation — we don't act as a tax agent. We confirm which column applies before any file is prepared.
Velmont Crest supported our corporate tax preparation and provided valuable consultancy on VAT and bookkeeping guidance.
How to start
Most people who call us about CbCR are stuck on one of three things. Read the one that sounds like your situation — and note that for many the answer is simply "you're out of scope."
Trigger 01 · Scope
Someone mentioned Country-by-Country Reporting and now you want a straight answer. The question is whether the group's consolidated revenue reaches AED 3.15 billion — which for most businesses it doesn't. We test the threshold and put the answer in writing.
A clear yes or no
Trigger 02 · Report
A UAE entity is the Ultimate Parent, so the notification and the full CbC report both fall due here. The report has to be built to the OECD three-table format within 12 months of the year-end. We assemble the per-jurisdiction data and coordinate the MoF filing.
Filed within 12 months
Trigger 03 · Notification
The report is filed abroad by the parent, but each UAE constituent entity still owes a CbC notification before the fiscal year-end, identifying who files and where. We prepare and submit the notification so that obligation isn't left open.
Notification, on time
How we work
Four stages, keyed to Cabinet Decision 44 of 2020 and the two CbCR deadlines. Same people throughout, so nobody has to relearn your group.
On engagement
We start by testing the group's consolidated revenue for the preceding financial year against the AED 3.15 billion CbCR threshold and identifying where the Ultimate Parent Entity sits. If the group is below the threshold, we tell you plainly that no CbC obligation applies. If it is in scope, we map which UAE entities are constituent entities and whether any of them is the Ultimate Parent or a Surrogate Parent — the fact that decides what has to be filed here versus overseas.
Once scope is clear
For each in-scope UAE constituent entity we prepare the CbC notification, stating its filing status and, where the report is filed by the parent in another jurisdiction, identifying the reporting entity and jurisdiction. We calendar the notification against the group's reporting fiscal year-end and submit it through the Ministry of Finance portal, so the notification obligation is met before the deadline.
The data
Where a CbC report is due in the UAE, we assemble the per-jurisdiction data from the group's consolidation — revenue split related and unrelated, pre-tax profit, tax paid and accrued, stated capital, accumulated earnings, headcount and tangible assets — into the OECD three-table format. Every figure is reconciled to the group accounts and cross-checked against the Master File and Local File, so the report is internally consistent before it is filed.
Final stage
We coordinate the submission of the CbC report through the Ministry of Finance portal within the 12-month window, confirm both the notification and the report are logged, and set the group up to repeat the cycle each reporting fiscal year. Because CbCR sits on the same annual rhythm as the transfer pricing documentation and the group audit, the following year's filings become a routine refresh rather than a rebuild.
Real deliverables
CbCR looks like two filings, but the work behind them is a file. Here's everything an in-scope group ends up with by the time the report is logged.
A written assessment of the group's consolidated revenue against the AED 3.15 billion threshold and where the Ultimate Parent sits, so scope is settled — including a plain out-of-scope answer where that's the case.
Prepared for each in-scope UAE constituent entity, stating its filing status and identifying the reporting entity and jurisdiction, and submitted through the Ministry of Finance portal before the fiscal year-end.
The full OECD three-table report — jurisdictional overview, constituent-entity listing and additional information — built where a UAE entity is the Ultimate or Surrogate Parent and filed within the 12-month window.
Revenue split related and unrelated, pre-tax profit, tax paid and accrued, stated capital, accumulated earnings, headcount and tangible assets per jurisdiction, reconciled to the audited group accounts.
A cross-reference showing the CbC report tells a story consistent with the group's Master File and Local File, so the three tiers of transfer pricing documentation reconcile rather than contradict one another.
Both the notification and report deadlines mapped to the group's reporting fiscal year, with confirmation that each filing was logged on the MoF portal and a schedule for the following year's refresh.
Every document is retained and indexed against the file, so each reporting fiscal year the notification and report are a routine refresh keyed to the group's year-end — and the fixed and daily penalties for a missed filing never come into play.
Why Velmont
Whoever tests your group revenue against the threshold and assembles the per-jurisdiction data is who answers when you ask whether a newly acquired subsidiary changes your filing status. No account manager relaying questions to a technician you never meet.
"Our year-end is 31 December — when is the notification due, and does the parent's overseas filing cover us?" That kind of question gets a real reply before end of business, not a ticket number and a three-day wait.
We're a UAE accounting practice. We prepare and coordinate the CbC notification and report and the MoF-portal filing for in-scope groups. We don't act as a tax agent, we don't represent you before the authority, and the first thing we'll tell most SMEs is that they're below the AED 3.15 billion threshold and this simply doesn't apply. Where a contentious position needs a formal opinion, we refer you to a registered advisor and hand over a ready file.
CbCR runs on the same annual rhythm as the transfer pricing documentation and the group audit. We build the notification and report on that cycle, so once the first year is done the following years become a routine refresh keyed to the fiscal year-end rather than a rebuild each time.
Recent insights
Start with what in-scope UAE groups actually have to file, then the transfer pricing documentation CbCR sits on top of, then the corporate tax regime the whole thing lives inside. Read them before the notification is due, not after a deadline slips.
Foundation
The AED 3.15B threshold, notification and report deadlines, the OECD three-table format and the penalties for a missed filing. The plain-English starting point.
Read moreDocumentation
Arm's-length principle, the Master File and Local File, OECD methods and the disclosure form. The documentation layer beneath the CbC report.
Read moreCorporate tax
The regime CbCR and transfer pricing sit inside — registration, the annual return and the related-party rules every large group has to reckon with.
Read morePricing
Fixed scope by obligation after a threshold and scope review. This applies only to MNE groups at or above the AED 3.15 billion consolidated-revenue threshold — if you're below it, there's nothing to quote and we'll say so.
CbC notification
Custom quote on request
The CbC notification for a UAE constituent entity of an in-scope MNE group.
CbC report
Custom quote on request
Full CbC report where a UAE entity is the Ultimate or Surrogate Parent.
Group coordination
Custom quote on request
Coordination across every UAE constituent entity of the group.
Talk to our experts
Send us a few lines about the group — your consolidated revenue, where the Ultimate Parent sits, and your reporting fiscal year-end. We'll write back within one UAE business day, tell you honestly whether you're in scope at all, and if you are, which filings you owe and a fixed scope. No meter running.
Honest scope
Some parts of a CbCR matter belong with a registered tax agent, a legal adviser or the authority itself — and for most businesses, CbCR doesn't apply at all. Velmont Crest is honest about both boundaries up front.
Need formal representation or a contentious tax opinion? We coordinate with registered advisers, with no conflict and no kickback.
CbCR applies only to MNE groups at or above AED 3.15 billion in consolidated revenue. If your group is below the threshold, there is no notification and no report to file, and we'll tell you that plainly rather than sell you a filing you don't owe.
CbCR is administered by the Ministry of Finance, and formal representation requires a registered tax agent. We prepare and coordinate the notification and report and brief the agent where representation is needed, but the agent-of-record role belongs with a registered firm.
Where a group's characterisation or reporting position is genuinely contentious, that calls for a registered tax agent or a legal adviser. We prepare the documentation and assemble the data; the formal opinion is theirs.
The CbC report is assembled from the group's consolidated figures. We reconcile our tables to those accounts, but we don't audit them or restate the group's numbers — the underlying consolidation stays with the group's auditor and finance function.
Whether the Ministry of Finance or a partner jurisdiction raises a query on exchanged CbC data sits with the authorities. What we control is that the report is complete, reconciled and consistent with the group's transfer pricing documentation — we won't promise an acceptance only the authority can give.
FAQs
Country-by-Country Reporting is an OECD BEPS Action 13 measure, implemented in the UAE by Cabinet Decision No. 44 of 2020 and administered by the Ministry of Finance. It requires large multinational enterprise (MNE) groups to report, for each tax jurisdiction they operate in, key figures such as revenue, profit before tax, tax paid and accrued, employees and tangible assets. It is the top tier of the OECD's three-tier transfer pricing documentation — Master File, Local File and CbC report — and it exists so tax authorities can see how a group's profit and tax are spread across jurisdictions. Velmont Crest prepares the notification and the report and coordinates the MoF-portal filing for in-scope UAE members and parents.
CbCR is a large-group-only obligation. It applies to UAE-headquartered MNE groups whose consolidated group revenue is at least AED 3.15 billion in the preceding financial year, and to UAE entities that are the Ultimate Parent Entity of such a group. It does not apply to SMEs — the overwhelming majority of UAE businesses are far below the AED 3.15 billion threshold and have no CbC notification or report to file at all. If you are unsure, the first thing to do is test your group's consolidated revenue against the threshold, which is where we start.
The threshold is AED 3.15 billion of consolidated group revenue in the financial year preceding the reporting fiscal year. This mirrors the OECD's EUR 750 million threshold expressed in dirhams. A group whose consolidated revenue is below AED 3.15 billion is not an in-scope MNE group and has no CbC obligation. A group at or above it is in scope, and its UAE constituent entities must handle the notification — and, where a UAE entity is the Ultimate Parent, the report as well.
They are two separate obligations on two separate deadlines. The CbC notification is a short filing every UAE constituent entity of an in-scope group must make before the end of the group's reporting fiscal year, stating its status and identifying which entity and jurisdiction will file the actual report. The CbC report is the full jurisdiction-by-jurisdiction data return, due within 12 months of the end of the reporting fiscal year, and it is filed in the UAE where a UAE entity is the Ultimate Parent (or a Surrogate Parent). A group can owe a notification here while the report is filed overseas by the parent.
The CbC notification is due before the end of the group's reporting fiscal year — so for a group with a 31 December year-end, the notification for that year has to be filed by 31 December. The CbC report is due within 12 months of the end of the reporting fiscal year — for the same group, by the following 31 December. Because the two run on different clocks, we map both dates to your group's fiscal year at the scope stage and file each to its own deadline through the Ministry of Finance portal.
A CbC report follows the OECD three-table format. It breaks the group down by tax jurisdiction and reports, per jurisdiction: revenue split into related-party and unrelated-party amounts, profit or loss before income tax, income tax paid on a cash basis, income tax accrued for the year, stated capital, accumulated earnings, number of employees and tangible assets other than cash and cash equivalents. A second table lists each constituent entity by jurisdiction and its main business activities, and a third allows additional explanatory information. We assemble these from the group's consolidation data and reconcile them to the audited group accounts.
CbCR is the top of the same three-tier documentation the OECD sets out for transfer pricing: the Master File describes the group globally, the Local File documents each entity's controlled transactions, and the CbC report gives the high-level per-jurisdiction picture. They have to tell a consistent story — a CbC report that contradicts the Master File is a red flag to a reviewer. For a group that is already maintaining a Master File and Local File under the UAE transfer pricing rules, we prepare the CbC report so it aligns with that documentation. If you need those lower tiers, our transfer pricing service covers them.
A failure to file the CbC notification or the CbC report carries a fixed administrative penalty of AED 1,000,000, plus a further AED 10,000 for each day the failure continues. Additional penalties can apply for providing incomplete or inaccurate information. Because these are significant and the two deadlines are firm, the practical protection for an in-scope group is to confirm scope early and calendar both the notification and the report the moment the obligation is established — which is the readiness we prepare.
No. Velmont Crest is a UAE accounting practice. CbCR is administered by the Ministry of Finance, and we support in-scope UAE members and parents of MNE groups by preparing the CbC notification and CbC report, assembling the per-jurisdiction data and coordinating the MoF-portal filing. We do not act as a registered tax agent, we do not provide formal representation, and we do not guarantee a particular authority outcome. Where a contentious position or formal representation is needed, we coordinate with a registered advisor and hand over a documentation file that is ready to work from. For most SMEs the honest answer is simpler still — you are below the threshold and this does not apply to you.
CbCR applicability in the UAE turns on one figure: whether the group's consolidated revenue reached AED 3.15 billion in the financial year preceding the reporting fiscal year. If it did, the group is an in-scope MNE group and its UAE constituent entities have a CbC notification obligation — and, where a UAE entity is the Ultimate Parent, a CbC report obligation too. If it did not, CbCR simply does not apply and there is nothing to file. There is no partial or sliding scope: you are either an in-scope MNE group at or above AED 3.15 billion or you are out of scope. We confirm which side of that line your group sits on in writing before any work begins.
The CbC notification in the UAE is submitted electronically through the Ministry of Finance's Country-by-Country Reporting portal, not through the FTA's corporate tax or VAT systems — CbCR is administered separately by the MoF. Each UAE constituent entity of an in-scope group registers and files its own notification stating its status and, where the report is filed abroad, the reporting entity and jurisdiction. We prepare the notification content, calendar it against your reporting fiscal year-end and coordinate the MoF-portal submission so the record is logged before the deadline. Where a full CbC report is due, that too is submitted through the same MoF portal within the 12-month window.
Yes. Country-by-Country Reporting is a federal UAE measure under Cabinet Decision No. 44 of 2020, so a country-by-country report for a Dubai group — mainland or free zone — follows the same AED 3.15 billion threshold, the same OECD three-table format and the same Ministry of Finance filing route as anywhere else in the Emirates. Free-zone status does not change CbCR scope: what matters is the group's consolidated revenue and where the Ultimate Parent sits. A Dubai-headquartered group over the threshold files its CbC notification and CbC report with the MoF exactly as an Abu Dhabi or Sharjah group would.
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