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UAE ESR Submission Deadline 30th September (400k fines?)

A friend of mine just emailed me a notification about an ESR submission deadline.

Does anyone have any clue what this is about?

Is it something freezones need to submit?

First I've heard of it!
Failure to submit the reports or failure to meet the economic substance test would result in penalties.

1st year = AED 50,000 penalty + Information exchange with foreign competent authorities
2nd consecutive year =AED 400,000 penalty + Information exchange with foreign competent authorities + Suspension, cancellation or non-renewal of trade license

You should put in place demonstrable documentary evidence supporting the Economic Substance Tests and documenting the basis of preparing the report, which may be subject to audit up to a period of six years from the end of the FY.

As a proponent of cross-border structures, I'd like to highlight that entities that are tax residents outside of the UAE are exempt from Economic Substance Reporting (only need to submit notice)