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Submission of CBCR Notification to MOFA
by Mr. Adnan Manzoor | DEC 23, 2019

All multinational groups with Group Revenue equal to or exceeding 3.15 Billion AED must read this carefully. Otherwise, there is a risk of AED 1,000,000 penalty if the form is not submitted by 31 December 2019.

Ministry of Finance (MoF) has required all eligible entities to submit CbCR notifications before the 31 December 2019 deadline. The purpose of reporting is to eliminate gaps in information between taxpayers and tax administrators. Cabinet Resolution No. 32 on Country-by-Country Reporting regulation was issued in UAE on 30th April 2019 and requires those entities which are tax residents in the UAE and part of a multinational group; to file a notification to the Ministry of Finance in a specified format.

Applicability of Resolution:

Multinational groups with consolidated revenues of at least AED 3.15 billion (approximately USD 855 million) per annum and wherein,

  1. An Ultimate Parent Entity established in the UAE being tax resident (being parent company of a Multinational Group)
  2. A Constituent Entity, through ownership or control of a Multinational Group in UAE.

Compliance Requirements:

CbCR Notification

Notification must be submitted, on or before the last day* of the group's financial year by the Constituent Entity of an MNE Group being Tax Resident of UAE.

     *Where financial reporting year of the Multinational group starts on 1st January 2019, the due date of first notifications must be on or before 31 December 2019

CbC Report Filing

The filing must be done within 12 months from the end of group financial year* by:

    1. Parent Company being Tax Resident in UAE
    2. Constituent Entity (being tax resident) on fulfilling certain conditions.

Penalties for Non- compliance:

Failure to keep the documents and information for a period of 5 years from the date of submitting CbCR AED 100,000
Failure to provide any information required in accordance with the CbCR and notification AED 100,000
Failure to report or notify on or before the due date

AED 1,000,000 plus

AED 10,000 per day subject to maximum AED 250,000

Failure to provide complete and accurate information AED 50,000 – 500,000


How Affiniax Partners can Help

  • Assessment of applicability of Regulation CBCR requirements
  • Assist in Notification Compliances
  • Assist in aggregating the data required under the CbC Reporting
  • Advisory services

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