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FTA Approved Tax Agent

Country By Country Reporting

Cabinet Resolution For County By Country Reporting

In 2018 UAE has signed the Multilateral Convention (“MLI”) to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“BEPS”) issued by Organisation for Economic Co-operation and Development (“OECD”).UAE has introduced Country by Country reporting (“CbC reporting”) by issuing Cabinet Resolution no. 31 of 2019, which come into force effect from 30th April 2019. This CR is issued on Organizing the Reports Submitted by Multinational Corporations’, setting out Country-by-Country Reporting (CbCR) compliance obligations (UAE CbCR rule) for multinational entity groups (MNE) based and/or operating in the UAE, effective for financial years commencing on or after 1 January 2019 (“FY19” or “reporting period”).

Cbc Report & Notification Filing Requirement

  • The CbC report must be submitted within 12 months of the end of the reporting period. Accordingly, for the financial years commencing on 1 January 2019, the CbC report must be submitted by 31 December 2020.
  • Notifications to the UAE MoF shall therefore be due by the last day of the reporting period (i.e., by 31 December 2019).
  • Failure to retain documents & information – 5 years - 100,000
  • Failure to provide information to MoF 100,000
  • Delay in submission of CbC report (within 12 months from the end of 12 months of reporting period) - 1,000,000 (+ 10,000 per day max 250,000)
  • Failure to ensure correctness & accuracy of the information in the CbC report. - 50,000 to 500,000

How Mac & Ross Can Help You

  • To analyze the group structure & identify the entities qualify for CbC as the UPE of MNE group.
  • To identify the entities which are failing under other Tax jurisdiction another country
  • Assistance in preparation of information for CbC reporting & notification.
  • Assistance in submission of the notification information & CbC report with the MoF.