A Practical Guide to Country-by-Country Report (CbCR) Filing
Once a UAE group crosses the Country-by-Country Reporting threshold, the calendar takes over: a Notification deadline, a twelve-month filing deadline, an XML schema that rejects on the smallest formatting error, and a Ministry of Finance portal that treats notification and report as two independently penalised obligations. PNPC's Dubai desk runs the CbCR filing calendar end to end — threshold testing, Reporting Entity determination, MoF portal notification, XML Schema-compliant report preparation from your group's consolidated financial data, submission, and the acknowledgement trail your Corporate Tax file will need. We have filed for group entities headquartered in India, the UAE, and across the GCC since Cabinet Resolution No.
What You're Really Buying
Country-by-Country Report (CbCR) filing is the operational, deadline-driven compliance obligation that sits under the OECD's BEPS Action 13 framework as implemented in the UAE by Cabinet Resolution No. 44 of 2020 (as amended by subsequent Cabinet and Ministerial Decisions), administered by the Ministry of Finance (MoF) — not the Federal Tax Authority, which is a distinction that catches many groups off guard since every other UAE tax obligation in recent years has moved through the FTA. Filing is a two-part exercise, and the two parts are assessed and penalised independently: a CbCR Notification, submitted annually through the MoF's CbCR portal identifying the Reporting Entity, its tax jurisdiction, and the UAE entity's role in the group (Ultimate Parent Entity, Surrogate Parent Entity, or Constituent Entity relying on another jurisdiction's filing); and the CbCR itself, an XML Schema-formatted report containing the group's revenue, profit before tax, income tax paid and accrued, stated capital, accumulated earnings, headcount, and tangible assets, broken out jurisdiction by jurisdiction, filed by the Reporting Entity within twelve months of the fiscal year end.
For the full scope, current process and what PNPC includes, see the dedicated Country-by-Country Report (CbCR) Filing service page.
Signs This Applies to You
- Your MNE Group's total consolidated group revenue in the preceding fiscal year meets or exceeds the threshold prescribed under Cabinet Resolution No.
- The UAE entity is the Ultimate Parent Entity of the group, tax resident in the UAE, and therefore the default Reporting Entity obligated to file the CbCR itself
- The UAE entity has been nominated as Surrogate Parent Entity by the group — often done to file once centrally rather than have every constituent jurisdiction chase a foreign UPE for data
- The UAE entity is a Constituent Entity (not the filer) but still needs its annual CbCR Notification submitted confirming who is filing and where — this obligation exists even when the UAE entity itself owes zero report
Before You Assume You Need This
- Your group's consolidated revenue sits below the prescribed threshold — no Notification or Report is due, though PNPC still recommends an annual threshold test since group revenue can cross the line without local management noticing
- You need help deciding whether your intercompany pricing is defensible or want a Master File/Local File prepared — that is transfer pricing documentation and arm's-length advisory, a related but analytically distinct engagement PNPC also offers
- You have not yet determined which group entity qualifies as the Reporting Entity or whether the UAE entity is UPE, Surrogate Parent, or a plain Constituent Entity — that determination should be settled first as a short advisory step before the filing engagement is scoped
Quick Answers
What exactly is a Country-by-Country Report, and who administers it in the UAE?
It is an annual report required under the OECD's BEPS Action 13 framework, breaking down a multinational group's revenue, profit before tax, tax paid and accrued, capital, earnings, headcount, and tangible assets on a jurisdiction-by-jurisdiction basis. In the UAE it is governed by Cabinet Resolution No. 44 of 2020 (as amended) and administered by the Ministry of Finance (MoF) — not the Federal Tax Authority, which handles VAT and Corporate Tax. Filing happens on a separate MoF portal from EmaraTax.
What is the revenue threshold that triggers a CbCR obligation for a UAE group?
The obligation applies where the MNE Group's total consolidated group revenue in the immediately preceding fiscal year meets or exceeds the threshold prescribed under Cabinet Resolution No. 44 of 2020 and related Ministerial Decisions — a figure aligned with the OECD's own recommended CbCR threshold. Because the exact figure is periodically confirmed and can be expressed differently depending on reporting currency, PNPC confirms the applicable threshold against the current Cabinet Resolution and Ministerial guidance at the start of every engagement rather than relying on a remembered figure from a prior year.
Is the threshold based on the UAE entity's turnover or the whole group's revenue?
The whole group's consolidated revenue — not the UAE entity's standalone turnover. A UAE subsidiary with modest local revenue sitting inside a large global group can still trigger a CbCR obligation for the group, and the UAE entity may still owe an annual Notification even if it is not the entity that files the full Report.
Working With PNPC Global
If your group has crossed the CbCR threshold — or you are not certain whether it has — talk to PNPC's Dubai desk before the Notification deadline, not after a portal rejection or an MoF query forces the conversation.
PNPC Global has advised Dubai businesses since 1986. Explore the full UAE Taxation & Regulatory Compliance practice for related services, or go straight to the Country-by-Country Report (CbCR) Filing page for specifics.
Rates, thresholds and filing dates are set by the relevant authority and revised periodically. Treat anything numeric here as "ask PNPC for the current figure," not as a quoted fact.