Cabinet Resolution No. 32 on Country-by-Country Reporting (CbCR Reporting)was issued in UAE and requires the entities being tax resident in the UAE and is part of a multinational group; to file notification form released by the Ministry of Finance (MOF).
Applicability of Resolution:
Multinational groups with consolidated revenues of at least AED 3.15 billion (approximately USD 855 million) per annum and wherein,
- An Ultimate Parent Entity established in the UAE being tax resident (being the parent company of a Multinational Group)
- A Constituent Entity, through ownership or control of a Multinational Group in UAE.
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 starting on 1st January 2019, the due date of first notifications must be on or before 31 December 2019
CbC Report Filing
Filing must be done within 12 months from the end of group financial year* by:
- Parent Company being Tax Resident in UAE
- 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 Spectrum can Help
- Assessment of applicability of Regulation 32
- Assist in Notification Compliances
- Assist in aggregating the data required under the CbC Reporting
- Advisory services
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