United Arab Emirates: Common Reporting Standards In The UAE

Last Updated: 18 October 2017
Article by Michael Kortbawi

The UAE's commitment to sharing financial data on individuals and entities under Common Reporting Standards (CSR) has been furthered reinforced by the Insurance Authority Board of Directors Decision No. 32 of 2017 Concerning the Common Reporting Standard Regulation.

The Common Reporting Standard is the brainchild of the OECD (Organization for Economic Cooperation & Development) and acts as the global standard for the collection and mutual exchange of financial information of tax residents, with over 100 countries party to the agreement it applies to both individuals and legal entities. The UAE which is party to the agreement will especially have its work cut out being a country where almost 84% of the population is made up of expatriates.

The Common Reporting Standard requires jurisdictions to obtain information from financial institutions who are obligated to report the different types of accounts and taxpayers as well as the due diligence procedures to be followed by the financial institutions. The OECD aims to end financial secrecy in global asset holdings, promote a greater level of transparency on foreign income and reduce instances of tax evasion. Financial institutions obligated to report include banks, custodians, insurers, asset managers, trusts and foundations.

Overview of Decision No. 32 of 2017

Article 3 – Grants the UAE Insurance Authority the power to enter the premises of a Reporting Financial Institution for the purpose of verifying the information submitted and ensuring compliance with the Regulation. Compliance is not optional and non-complying Financial Institutions will be open to the penalties prescribed by the Regulation.

Article 4 – Requires Reporting Financial Institutions to retain a complete record of all information submitted for a period of five years after the date of reporting to the Insurance Authority. Financial Institutions will be able to use this data for analytical purposes to identify and understand key financial trends in reportable jurisdictions.

Article 5 – Permits harsh penalties for instances of non-compliance with the Regulations. Fines range from AED 10,000 for minor infractions to AED 250,000 for cases of significant non-compliance. In the instance of a Financial Institution affirming a false self-certification, they shall be subject to an AED 25,000 penalty. It is unclear whether a resident will be penalized for knowingly providing false self-certification.

General Due Diligence Requirements – Reporting Financial Institutions must provide information on reportable accounts annually. If Financial Institutions do not have the capacity to provide such reports, external service providers can be employed to fulfill such reporting and due diligence requirements.

High Value Accounts – Will be subject to an enhanced review process including review of all electronic searchable data (and paper searchable data if the electronic data doesn't contain all the information required). High value accounts will be treated as Reported Accounts if the account relationship manager has knowledge that the account is held for tax purposes in another jurisdiction.

Individual Accounts – Reporting Financial Institutions must obtain a self-certification to determine the account holder's residence for tax purposes. The account will be treated as a reportable account if the self-certification establishes that the holder is a resident for tax purposes in a reportable jurisdiction.

Pre-existing Entity Accounts – Only accounts with an aggregate balance or value in excess of 250,000 USD as of December 31st, 2016 or calendar year must be reviewed in accordance with the Regulations. Review of such accounts must be completed by December 31st, 2018.

New Entity Accounts – will be considered as Reportable Account if it can be established that the account holder is a resident in a reportable jurisdiction. If the account holder is a passive NFE with one or more of the controlling persons being a reportable person then the account shall be considered reportable.

What are the Implications for Reportable Financial Institutions?

Financial Institutions have a responsibility to take necessary steps to identify 'reportable accounts', whereby the beneficial owner of the account is a resident of a reportable jurisdiction, meaning a jurisdiction which has signed up to the CRS. Once 'reportable accounts' have been identified, Financial Institutions are obligated to annually report the financial information to the local authorities who will, in turn, pass that information on to the tax authorities where the account holder is resident.

While the cross-border exchange of account information is vital to the global effort to crackdown on tax evasion, it poses many difficulties for Financial Institutions who now face the burden of compliance costs and an increased risk of legal exposure should they fail to comply with the Regulation.

Financial Institutions also need to be extremely vigilant when it comes to data protection of confidential information. As they are required to share the tax information of local residents with government agencies, they need to comply with data protection procedures of a reportable jurisdiction which may or may not be the same as in the UAE.

It remains to be seen how the UAE Financial Institutions will fare under their CRS obligations as the first exchange of information is scheduled to occur on September 30TH, 2018. The success of CRS will be dependent on a reciprocal exchange of information with all countries exercising a high standard of due diligence, without this it amounts to little more than a costly exercise.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

In association with
Related Topics
Related Articles
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions

Mondaq.com (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of www.mondaq.com

To Use Mondaq.com you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions