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DOING BUSINESS in UAE






                                                              ‘financial reporting years’ starting on or
             Country-by- Country
                                                              after January 1st 2019. The reporting is on an
                 Reporting (CbCR)                             annual basis.


                                                              The ultimate parent entity (UPE) of a
       Country by Country (CbC) Reporting is
                                                              multinational group of companies (MNE)
       part of Action 13 of the Base Erosion and
                                                              who is  a “tax resident”  in UAE  and its
       Profit Shifting (BEPS) initiative led by the
                                                              consolidated revenues equal to or are more
       Organisation  for  Economic  Co-operation
                                                              than AED 3.15 billion in the previous financial
       and Development (OECD) and the Group of
                                                              year is subject to the CbCR rules.
       Twenty (G20) industrialised nations.

       BEPS Action 13 requires large Multinational
       Groups of Entities (MNEs) to file a CbC Report
       that should provide a breakdown of the
       Multinational Group’s global revenue, profit
       before tax, income tax accrued, and some
       other indicators of economic activities for
       each jurisdiction in which the MNE operates.
       The purpose  of CbC Reporting  is to
       eliminate any gap in information between
       the taxpayers and tax administrations
       with regard to information on where the
       economic value is generated within the MNE
       Group and whether it matches where profits
       are allocated and taxes are paid on a global
       level.

       In the UAE, CbCR requirements are applicable
       to the UAE-headquartered MNE Groups with

                                                              in the UAE (unless exemptions apply) to
                                                              prepare and file a Ultimate Beneficial Owner
                                                              (“UBO”) register, Nominee Director register (if
         Ultimate Beneficial Owner
                                                              applicable) and a Partners or Shareholders
                                                              register, with the relevant authority within
                                                              sixty (60) days from the date the Resolution
       Beneficial Owner Procedures came into
                                                              came into effect, being 27 October 2020, or
       effect in 2020. The Resolution introduces
                                                              by the date the entity is established.
       new requirements for entities to disclose its
       beneficial owners. The main purpose is to
                                                              The Resolution applies to all entities licensed
       enhance transparency of entities registered
                                                              in the UAE, excluding the following:
       in the  UAE, as well  as to develop  effective
       and sustainable executive and regulatory
                                                              • Entities in financial free zones (Abu Dhabi
       mechanisms and procedures in respect of
                                                              Global Markets and Dubai International
       beneficial owner data.
                                                              Financial Centre); and
                                                              •  Entities which are directly or indirectly
       This Resolution requires entities licensed
                                                              wholly owned by Federal or Emirate
                                                              government.


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