# CbCR UAE: country-by-country reporting rules for multinational groups

> CbCR UAE rules explained: who files, deadlines, thresholds, and penalties for country-by-country reporting in the UAE.

Source: https://einvoicedirect.ae/uae-corporate-tax/cbcr-uae  
Last updated: 2026-06-05  
Publisher: EInvoice Direct (Massive FZCO), UAE e-invoicing software.

## What is CbCR UAE?

CbCR UAE is the country-by-country reporting regime that applies to large multinational enterprise (MNE) groups headquartered in the United Arab Emirates. It requires the ultimate parent entity of an MNE group with consolidated revenue of AED 3.15 billion or more to file an annual report showing income, taxes, and business activity in every country where the group operates.

Country-by-country reporting sits inside the wider [UAE Corporate Tax](https://einvoicedirect.ae/uae-corporate-tax) framework and aligns the UAE with the OECD Base Erosion and Profit Shifting (BEPS) Action 13 standard. It is a transfer pricing transparency tool, not a tax return. The CbCR UAE report helps the Federal Tax Authority (FTA) and partner tax authorities spot profit shifting between jurisdictions.

This guide explains who must file, the thresholds, deadlines, penalties, and how CbCR UAE fits alongside master file and local file duties. It is written for UAE finance teams, tax managers, and business owners who need a clear answer without wading through legal text.

## Who must file CbCR in the UAE?

CbCR UAE obligations fall on MNE groups that meet a revenue test. The main rule is simple: if the group's consolidated revenue in the prior financial year is AED 3.15 billion or more, the group is in scope.

Two parties can have a filing or notification duty in the UAE:

- The ultimate parent entity (UPE) if it is a UAE tax resident.
- A UAE-resident constituent entity of a foreign-headed MNE group, in some secondary filing cases or for notification purposes.

The AED 3.15 billion threshold mirrors the EUR 750 million OECD benchmark. Groups below this revenue level have no CbCR UAE filing duty, although they may still owe master file, local file, and disclosure obligations under [UAE Transfer Pricing Rules](https://einvoicedirect.ae/uae-corporate-tax/uae-transfer-pricing-rules).

### The legal basis

CbCR UAE was first introduced by Cabinet Resolution 44 of 2020, later amended by Cabinet Resolution 55 of 2023. It now operates alongside the corporate tax regime under Federal Decree-Law 47 of 2022. Transfer pricing documentation duties, including master file and local file rules, are set out in Ministerial Decision 97 of 2023.

### Who is a constituent entity?

A constituent entity is any business unit included in the consolidated financial statements of the MNE group. This includes:

- Subsidiaries consolidated on a line-by-line basis.
- Permanent establishments that prepare separate financial statements.
- Entities excluded from consolidation only because of size or materiality.

## CbCR UAE thresholds and key dates at a glance

| Item | Detail |
| --- | --- |
| Revenue threshold | AED 3.15 billion consolidated group revenue in the prior financial year |
| Reporting fiscal year | Years starting on or after 1 January 2019 |
| Report filing deadline | Within 12 months of the end of the reporting fiscal year |
| Notification deadline | By the last day of the reporting fiscal year |
| Filing portal | UAE Ministry of Finance CbCR portal |
| Currency | AED or the group's reporting currency |
| Format | OECD XML schema |

## What goes inside a CbCR UAE report?

The CbCR report is split into three tables that follow the OECD template. Each table covers the whole MNE group and breaks the numbers down by tax jurisdiction.

### Table 1: financial and tax data by jurisdiction

Table 1 lists every country where the group has constituent entities. For each country, you report:

- Revenue from unrelated parties.
- Revenue from related parties.
- Total revenue.
- Profit or loss before income tax.
- Income tax paid on a cash basis.
- Income tax accrued for the current year.
- Stated capital.
- Accumulated earnings.
- Number of employees.
- Tangible assets other than cash and cash equivalents.

### Table 2: list of constituent entities

Table 2 names every entity in the group, the country where it is a tax resident, the country of organisation if different, and the main business activities. Activities use OECD categories such as research and development, holding shares, manufacturing, sales, and internal group finance.

### Table 3: additional information

Table 3 is a free-text section. Use it to explain unusual items, currency conversion choices, the data source (consolidated accounts, statutory accounts, or internal management accounts), and any restructuring that affected the numbers.

## The CbCR UAE notification rule

Every UAE-resident constituent entity of an in-scope MNE group must file a notification with the FTA. The notification tells the authority:

- Whether the UAE entity is the ultimate parent or a surrogate parent.
- If not, the identity and tax residence of the entity that will file the report.
- The reporting fiscal year covered.

The notification is due by the last day of the reporting fiscal year. For a calendar year group, that is 31 December. Missing the notification triggers separate penalties even if the report itself is filed on time elsewhere.

## CbCR UAE penalties

Penalties under Cabinet Resolution 44 of 2020 are significant. They apply to both the report and the notification.

| Violation | Penalty (AED) |
| --- | --- |
| Failure to file the CbCR report on time | 1,000,000 plus 10,000 per day, capped at 250,000 |
| Failure to file the notification on time | 1,000,000 |
| Failure to keep supporting information | 100,000 |
| Filing incomplete or inaccurate data | 50,000 to 500,000 |
| Failure to provide information requested by the FTA | 100,000 |

These figures are separate from corporate tax penalties under Federal Decree-Law 47 of 2022 and from VAT or e-invoicing fines.

## How CbCR UAE fits with master file and local file

CbCR is one of three transfer pricing documents an MNE group may need. The trio comes from BEPS Action 13.

| Document | Trigger threshold | Focus |
| --- | --- | --- |
| CbCR report | Group revenue AED 3.15 billion | Group-wide tax footprint by country |
| Master file | UAE entity revenue AED 200 million or group revenue AED 3.15 billion | Group structure, intangibles, financing |
| Local file | Same thresholds as master file | UAE entity related party transactions |

For more on each document, see our guides to [UAE Transfer Pricing Documentation](https://einvoicedirect.ae/uae-corporate-tax/uae-transfer-pricing-documentation), the [Transfer Pricing Master File UAE](https://einvoicedirect.ae/uae-corporate-tax/transfer-pricing-master-file-uae), and the [Transfer Pricing Local File UAE](https://einvoicedirect.ae/uae-corporate-tax/transfer-pricing-local-file-uae). The disclosure form attached to the corporate tax return covers [Related Party Transactions UAE](https://einvoicedirect.ae/uae-corporate-tax/related-party-transactions-uae) and dealings with [Connected Persons UAE Corporate Tax](https://einvoicedirect.ae/uae-corporate-tax/connected-persons-uae-corporate-tax).

## Step-by-step CbCR UAE compliance checklist

Use this checklist to plan the year.

- Check group revenue against the AED 3.15 billion threshold using the prior year's consolidated accounts.
- Identify the ultimate parent entity and its tax residence.
- Identify every UAE-resident constituent entity in the group.
- Decide which entity will file the report and in which country.
- Submit the UAE notification by the last day of the fiscal year.
- Collect Table 1 financial data for every jurisdiction.
- Map constituent entities to business activities for Table 2.
- Draft Table 3 explanations for any unusual items.
- Convert the report to OECD XML format.
- File on the UAE Ministry of Finance portal within 12 months of year end.
- Keep working papers for at least 7 years.

## Worked example: when does CbCR UAE bite?

Consider a UAE-headquartered group with the 2024 consolidated revenue of AED 4.2 billion. It has subsidiaries in the UAE, Saudi Arabia, India, and the United Kingdom.

- Revenue exceeds AED 3.15 billion, so the group is in scope from fiscal year 2025.
- The UAE parent is the ultimate parent entity and must file the CbCR report.
- Each UAE subsidiary must file a notification by 31 December 2025.
- The CbCR report for fiscal year 2025 is due by 31 December 2026.
- Master file and local file are also due by 31 December 2026, alongside the corporate tax return.

If the same group later drops below the threshold, it stays out of scope until revenue crosses AED 3.15 billion again.

## Common CbCR UAE mistakes to avoid

- Missing the notification deadline. The notification carries its own AED 1,000,000 fine.
- Using statutory accounts in one country and management accounts in another without disclosing the mix in Table 3.
- Forgetting permanent establishments. A branch in another country is still a constituent entity.
- Ignoring dormant entities. They appear in Table 2 even with zero revenue.
- Double-counting intra-group dividends as revenue.
- Not reconciling employee headcount with HR records as of a consistent date.

## How CbCR UAE links to corporate tax filing

The corporate tax return is due within 9 months of the financial year end. The CbCR report is due within 12 months of the same year end. The tax disclosure form, master file, and local file are due with the corporate tax return.

This means the CbCR UAE process runs in parallel with the corporate tax cycle but has its own deadline and its own portal. Plan one project, two finish lines. Read the full [UAE Corporate Tax](https://einvoicedirect.ae/uae-corporate-tax) overview for the wider timeline.

Official sources to bookmark:

- [UAE Ministry of Finance](https://mof.gov.ae) for CbCR notifications and report filing.
- [UAE Federal Tax Authority](https://tax.gov.ae) for corporate tax registration and returns.

If you need a partner that can handle UAE tax documentation alongside e-invoicing readiness, you can [get UAE e-invoicing pricing](https://einvoicedirect.ae/for-businesses#contact) and see how EInvoice Direct supports finance teams through the 2026 and 2027 mandates. An accredited service provider is included with the software at no extra charge.

## Frequently asked questions

### What is the CbCR threshold in the UAE?

The CbCR UAE threshold is AED 3.15 billion in consolidated group revenue in the prior financial year. Multinational enterprise groups that meet or exceed this figure must file a country-by-country report and submit notifications. Groups below the threshold are out of scope for CbCR but may still owe master file, local file, and disclosure form obligations under UAE transfer pricing rules.

### When is the CbCR UAE filing deadline?

The CbCR UAE report is due within 12 months of the end of the reporting fiscal year. For a calendar year group reporting on fiscal year 2025, the deadline is 31 December 2026. The separate CbCR notification is due earlier, on the last day of the reporting fiscal year itself. Both deadlines are strict and carry significant penalties if missed.

### Who needs to file CbCR in the UAE?

The ultimate parent entity of an in-scope multinational group files the CbCR report if it is a UAE tax resident. Every UAE-resident constituent entity of an in-scope group, whether the parent or a subsidiary, must also file an annual notification with the Federal Tax Authority. The notification identifies which entity will file the full report and where.

### What is the penalty for not filing CbCR in the UAE?

Failure to file the CbCR report on time triggers a fine of AED 1,000,000 plus AED 10,000 per day, capped at AED 250,000 in daily penalties. Missing the notification carries a separate AED 1,000,000 fine. Incomplete or inaccurate data attracts AED 50,000 to AED 500,000. Failure to keep supporting records adds AED 100,000.

### How is CbCR different from master file and local file in the UAE?

CbCR is a group-wide report showing revenue, profit, and taxes paid in every country where the multinational operates. The master file describes the group's global structure and intangibles. The local file details the UAE entity's related party transactions. CbCR applies only above AED 3.15 billion group revenue, while master and local files apply at lower thresholds.

### Does CbCR UAE apply to free zone companies?

Yes. Free zone entities, including Qualifying Free Zone Persons (QFZPs), are constituent entities of their multinational group. If the group meets the AED 3.15 billion threshold, free zone subsidiaries appear in Table 2 of the CbCR report and must file their own notification with the Federal Tax Authority. Their 0% corporate tax status does not remove the CbCR duty.

### What format is used for CbCR UAE filing?

The CbCR UAE report follows the OECD XML schema published under BEPS Action 13. Filings are submitted through the UAE Ministry of Finance CbCR portal. The data must reconcile with the group's consolidated financial statements or another consistent source noted in Table 3. Working papers and source data should be retained for at least 7 years for audit purposes.


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