UAE · VAT

UAE VAT Registration, Returns, Refunds and Audit Support

UAE VAT is a transaction-level tax, which means the return is only as accurate as the treatment applied to each supply and each purchase. Federal Decree-Law No. 8 of 2017 sets the framework, its Executive Regulations supply the detail, and the Tax Procedures Law governs returns, audits, penalties and disputes.

Registration, groups and deregistration

Registration is mandatory once taxable supplies pass the mandatory threshold over the previous twelve months or are expected to exceed it in the next thirty days, and voluntary registration is available above the lower threshold. A non-resident making supplies in the UAE registers where no other person is obliged to account for the tax.

Related parties that meet the conditions may register as a tax group and be treated as a single taxable person. Grouping simplifies filing but concentrates liability, so the decision should follow an assessment of the members' recovery positions rather than convenience.

Place of supply and the reverse charge

For services the default place of supply is the supplier's place of residence, with exceptions that move it to the recipient, to the location of real property, or to the place of performance. Telecommunications and electronic services follow where they are used and enjoyed.

In the energy sector and on imports, the reverse charge applies: the recipient accounts for the tax on its own return. The supplier's protection depends on written confirmation from the recipient before the date of supply, and a false claim by a recipient is treated as tax evasion.

Input tax recovery, refunds and voluntary disclosures

Recovery requires a valid tax invoice, use of the purchase for taxable supplies, and payment of the consideration as the Regulations require. Zero-rated supplies preserve recovery; exempt supplies remove it, which is why confusing the two is a costly error rather than a labelling one.

Where an error is found in a filed return, a voluntary disclosure corrects it on the FTA's terms and usually on better terms than a correction discovered in an audit. We prepare the disclosure, quantify the exposure and align the accounting records to the corrected position.

FTA reviews and audits

An FTA review works from the VAT return back to the ledger and then to the invoices. Our audit support rebuilds the return from the accounting system, prepares the reconciliation for each tax period under review, and answers the sample requests with the source documents already indexed.

Questions we are asked

Can I recover VAT on costs incurred before registration?

Recovery of pre-registration input tax is available within the limits set by the Executive Regulations, including the look-back period for services. The claim is made on the first return with the supporting invoices.

What is the difference between zero-rated and exempt?

Zero-rated supplies are taxable at 0%, so related input tax stays recoverable. Exempt supplies carry no output tax but block recovery of the input tax attributable to them.

Do I need to issue an electronic invoice?

The e-invoicing framework is being introduced under the law and applies according to the timeline set for the relevant businesses. We confirm the applicable date and system requirements for each client rather than assuming a single start date.

Author and reviewer

Written by Zuhair Khairi, Senior Tax Advisor. Lawyer and certified auditor, 15 years in corporate tax, legal compliance and financial auditing across Iraq and the UAE.

Reviewed by Raad Hazar, Legal Advisor, Tax Law & Audit Support. Qualified lawyer (Humber College, Toronto) working on Iraqi and UAE tax law and audit defence files.

Last reviewed 31 October 2026. This page summarises legislation and authority practice as published at that date. Rates, deadlines and procedure change by decision and circular, so confirm the current position for your file before relying on any statement here.

Primary legislation referenced

  • Federal Decree-Law No. 8 of 2017 on Value Added Tax
  • VAT Executive Regulations
  • Federal Decree-Law No. 28 of 2022 on Tax Procedures

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