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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.

EUR 750m thresholdNotification even without reportGroup level

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

Group revenue thresholdEUR 750mAssessed at group level, in two of the four preceding years.
UAE ultimate parentFiles the reportThe full country-by-country report is submitted here.
UAE subsidiary of a foreign groupNotificationSeparately penalised — and the obligation nobody owns.
The notification is the obligation nobody owns: group tax assumes local handles it, and local assumes group does.

What to do

The filing, step by step.

  1. Test the group thresholdEUR 750 million consolidated revenue. This is assessed at group level, not for the UAE entity.
  2. Identify the ultimate parent and its residenceThis determines who files the report and where.
  3. File the UAE notification if you are a constituent entityIdentifying the reporting entity and its jurisdiction, within the deadline.
  4. Coordinate with group tax explicitlyThe gap between 'group handles it' and 'local handles it' is where notification failures live.
  5. Align with the Pillar Two positionIn-scope groups will also be considering the Domestic Minimum Top-up Tax.
The mistake people make. Assuming a UAE subsidiary has nothing to do because the parent files abroad. The notification obligation is separate, local, and separately penalised, and it is the one nobody owns.

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?