Tax & compliance
Country-by-country reporting
A group-level obligation at EUR 750 million of consolidated revenue. If a UAE entity is the ultimate parent, the filing is yours — and the notification obligation can apply even when the report is not.
The rule
What the law actually requires.
Country-by-country reporting requires multinational enterprise groups with consolidated revenues of EUR 750 million or more to report, for each jurisdiction in which they operate, the revenue, profit, tax paid and accrued, employees, capital and tangible assets attributable to that jurisdiction. Where the ultimate parent entity is UAE tax resident, the report is filed in the UAE. Constituent entities in the UAE that are part of an in-scope group but are not the ultimate parent generally have a notification obligation identifying who will file and where.
The notification is the part that catches UAE subsidiaries of foreign groups. The report itself is filed by the parent in its own jurisdiction, and the UAE entity has nothing to prepare — but it may still need to notify the authorities here of the identity and residence of the reporting entity, within a deadline, and a failure to do so is penalised independently of the group's overall compliance. Local finance teams in UAE subsidiaries frequently assume group tax handles everything, and group tax frequently assumes local entities handle local filings.
Thresholds and deadlines
- Threshold
- EUR 750m consolidated group revenue
- Report content
- Revenue, profit, tax, employees, capital and assets per jurisdiction
- UAE parent
- Files the report in the UAE
- UAE subsidiary
- Generally has a notification obligation
- Penalties
- Apply to notification failures independently
- Related
- Sits alongside the Domestic Minimum Top-up Tax
The compliance calendar
What to do
The filing, step by step.
- Test the group thresholdEUR 750 million consolidated revenue. This is assessed at group level, not for the UAE entity.
- Identify the ultimate parent and its residenceThis determines who files the report and where.
- File the UAE notification if you are a constituent entityIdentifying the reporting entity and its jurisdiction, within the deadline.
- Coordinate with group tax explicitlyThe gap between 'group handles it' and 'local handles it' is where notification failures live.
- Align with the Pillar Two positionIn-scope groups will also be considering the Domestic Minimum Top-up Tax.
Related
Questions
Only if it is part of a multinational group with consolidated revenues of EUR 750 million or more. Most UAE companies are far below this.
Generally the parent files the report in its own jurisdiction, but the UAE entity may still have a notification obligation here.
Revenue, profit before tax, tax paid and accrued, employee numbers, stated capital and tangible assets, broken down by jurisdiction.
It is separate but related. Both apply at the EUR 750 million threshold and both form part of the OECD framework.
One question
Which of these applies to your company?
Then it is carrying on a Relevant Activity for economic substance purposes, and a notification is due within six months of the financial period end whether or not it earned anything. The dormant holding vehicle is the entity most often in default.
ESR for holding companiesOr just ask usThen you are probably a Designated Non-Financial Business, with goAML registration, a named compliance officer and reporting obligations that are categorical rather than scaled to headcount. Non-registration is among the most heavily penalised failures in these sectors.
goAML and AML obligationsOr just ask usA residence visa does not do it. The certificate rests on days of presence or defined ties, is issued per treaty partner and per year, and the audience for it is the other country's revenue authority.
The residency conditionsOr just ask us