VAT in the UAE

Value added tax is a consumption tax collected in stages along a supply chain, but borne in full by the final consumer. A registered business charges 5% output tax on what it sells, deducts the input tax it was charged on its own purchases, and pays only the difference to the Federal Tax Authority. If input tax exceeds output tax in a period, the business is in a refundable position and can reclaim the excess. So yes; there is VAT in Dubai and in every other emirate. VAT is a federal tax, imposed by Federal Decree-Law No. 8 of 2017 and administered nationally by the FTA, so the rate and the rules are identical in Dubai, Abu Dhabi, Sharjah and everywhere else in the country. Individuals pay it at the till; businesses collect and remit it. The practical consequence is that VAT should be neutral for a fully taxable business and a real cost only for the end consumer, for exempt businesses that cannot recover input tax, and for anyone who fails to register when the law required it.

Three treatments exist, and the difference between the second and third is the one that costs businesses money. Standard-rated supplies carry 5%. Zero-rated supplies carry 0% but are still taxable supplies, so the supplier keeps the right to recover input tax and the value still counts toward the registration threshold. Exempt supplies carry no VAT and carry no right of recovery, so the VAT on related costs becomes a real expense.

Article 45 of Federal Decree-Law No. 8 of 2017 sets out the zero-rated list. Article 46 sets out the exempt list, and it is short: financial services specified in the Executive Regulation, residential buildings other than those zero-rated under Article 45, bare land, and local passenger transport.

Registration is a legal test, not a choice, once your numbers cross the line. Under Article 13 of the VAT Law read with Article 7 of the Executive Regulation, a person resident in the UAE must register when the value of taxable supplies and imports exceeded AED 375,000 over the previous twelve months, or when it is expected to exceed AED 375,000 within the next 30 days. The application must be filed within 30 days of becoming liable.

Voluntary registration is available under Article 17 where taxable supplies, imports or taxable expenses exceeded AED 187,500 in the previous twelve months, or are expected to in the next 30 days. Expenses count, which is what makes voluntary registration workable for a pre-revenue company that is incurring UAE VAT on set-up costs.

Non-resident businesses are treated differently. Under Article 13(2), a person with no place of residence in the UAE or another Implementing State must register if they make supplies here and no other person is obliged to account for the tax on those supplies. There is no threshold to hide behind: for a foreign supplier the effective threshold is nil, unless the UAE customer accounts for the tax under the reverse charge.

Registration is done through EmaraTax, the FTA's online platform, which replaced the older e-Services portal. The FTA lists the service fee as free and states a processing time of 20 business days from receipt of a complete application. On approval the FTA issues a Tax Registration Number and a VAT registration certificate, both of which can be downloaded from the EmaraTax dashboard. The TRN is what makes a tax invoice valid, so it is worth checking the ones your suppliers quote. The FTA publishes a TRN verification service on tax.gov.ae; entering the number returns the registered legal name. That check is the only reliable one. The FTA does not publish a digit-count or checksum rule for TRNs in the VAT Law or its Executive Regulation, so do not treat a number that merely looks right as evidence that a supplier is registered, verify it and keep the result.

Article 59(1) of the VAT Executive Regulation lists exactly twelve particulars, (a) to (l), that a full tax invoice must carry, and an invoice missing any of them is not a valid tax invoice for the recipient's input tax claim. The twelve are set out in the table below. Where the recipient has to account for the tax under the reverse charge, Article 59(1)(l) requires the invoice to state that the recipient is required to account for the tax and to refer to the relevant provision of the Decree-Law. Article 65(1) of the Decree-Law is the obligation to issue the invoice at all; Article 59 of the Regulation is what has to be on it.

Every registrant files a VAT return for each tax period, whether or not there were any transactions. Article 62(1) of the Executive Regulation sets the standard tax period at three calendar months ending on the date the Authority determines. Article 62(2) lets the FTA assign a shorter or longer period, and the grounds it gives are qualitative: the risk of tax evasion, the ability to monitor compliance and collect the tax, and the administrative and compliance burden: not a turnover figure. The widely republished rule that annual supplies above AED 150 million force monthly filing appears nowhere in the Regulation, and this page does not state it. Article 62(3) lets a person on the standard quarterly period ask the FTA to change the month that period ends on. Article 64(1) of the Executive Regulation requires the return to be received by the FTA no later than the 28th day following the end of the tax period, and the payable tax to be received by the same date, “or by such other date as directed by the Authority”, which is why the 28th is a default rather than an absolute.

Filing on time but paying late still triggers a late payment penalty: two separate obligations, one deadline. Article 64(2) adds the one people forget. A person whose registration has been cancelled must still file a final tax return for the last tax period. Missing that return is the same AED 1,000 late-filing penalty as any other. The return is filed in EmaraTax on form VAT 201. Box numbers follow the interface and have moved before; Article 64(5) of the Executive Regulation is the durable statement of what the return must allow you to report.

Under the reverse charge, the customer rather than the supplier accounts for the tax. In the simplest terms: you import a service from a foreign supplier who is not registered in the UAE and cannot charge you UAE VAT; instead you declare 5% output tax on the value in your own return and, if you are fully taxable, recover the same amount as input tax in that same return. The two entries cancel and the net cash effect is nil. That is the whole idea, it puts imports on the same footing as domestic purchases without asking every overseas supplier to register here. Article 48 of the VAT Law sets it out. Clause 1 applies it to imports of concerned goods and concerned services. Clause 3 applies a domestic reverse charge to supplies between UAE registrants of crude or refined oil, unprocessed or processed natural gas and pure hydrocarbons, where the recipient will resell them or use them to produce or distribute energy, subject to written declarations from the recipient confirming registration and intended use. Clause 8 lets the Cabinet extend the mechanism to other goods and services, which is how the domestic reverse charge on metal scrap was introduced by Cabinet Decision No. 153 of 2025.

A common misconception is that free zone companies are outside VAT. They are not. The overwhelming majority of UAE free zone entities are ordinary taxable persons with ordinary registration, invoicing and filing obligations. What changes for a small subset is the place of supply of goods.

Article 50 of the VAT Law provides that a designated zone meeting the conditions in the Executive Regulation is treated as outside the UAE. Article 51 of the Executive Regulation sets those conditions: a specific fenced geographic area with security measures and customs controls monitoring entry, exit and movement of goods; internal procedures for keeping, storing and processing goods; and an operator that complies with FTA procedures. The list of designated zones is set by Cabinet Decision No. 59 of 2017 and has been amended since, so always check the current list on the FTA legislation page rather than assuming a zone qualifies.

The relief is narrow and applies to goods, not services. Article 51(6) states that the place of supply of services is inside the UAE even where the supply is made in a designated zone. Goods supplied within a designated zone for consumption are also treated as supplied in the UAE. Transfers between designated zones can move without tax where the goods are not released, used or altered and the transfer follows customs suspension rules under the GCC Common Customs Law. And under Article 51(10), a person established or resident in a designated zone is still treated as resident in the UAE for VAT purposes.

Real estate is where the zero-rated and exempt categories do the most work, so the treatment turns on what is being supplied rather than on who is supplying it. Commercial property is standard rated. Sales and leases of commercial buildings, including offices, retail units and warehouses, carry 5%, and commercial rent carries 5%. Where a buyer purchases commercial property from a taxable person, the FTA operates a dedicated payment route: the buyer pays the VAT through the FTA portal and the resulting payment transaction number is required by the land department before the ownership transfer can complete. Residential property is exempt under Article 46(2), with one important carve-out. Under Article 45(9), the first supply of a residential building within three years of its completion is zero-rated, whether by sale or by lease, in whole or in part. Article 45(11) does the same for the first supply of a building converted from non-residential to residential. Every subsequent sale or lease of that residential building is exempt.

Bare land is exempt under Article 46(3). Land that is not bare, covered or partly covered by completed or partially completed buildings or civil engineering works, falls outside that exemption and is standard rated. There is no monetary de minimis: the exemption depends on the character of the land, not on the size of the deal.

There is no single UAE VAT refund. There are several distinct schemes, each with its own eligibility, form and deadline, and most disappointment comes from applying under the wrong one. Registered businesses in a net refundable position claim through the VAT refund request in EmaraTax under Article 65 of the Executive Regulation, or carry the credit forward. Nothing is repaid automatically: Article 74(3) of the VAT Law carries the excess forward where no request is submitted, Article 74(2) read with Article 39(1) of the Tax Procedures Law lets the FTA offset it against other liabilities first, and Article 9(2) of Cabinet Decision No. 74 of 2023 treats an overpayment as a credit against future liabilities unless you ask for it back. Two separate five-year clocks arrived on 1 January 2026, and they are routinely merged into one. Article 74(3) of the VAT Law, as amended by Federal Decree-Law No. 16 of 2025, lapses the carry-forward: excess recoverable tax carries forward for no more than five years from the end of the tax period in which it arose, after which the right to claim it lapses and it may not be used to settle any tax liability.

Separately, Article 38(2) of the Tax Procedures Law, as amended by Federal Decree-Law No. 17 of 2025, caps the refund application at five years from the end of the relevant tax period, with Article 38(6) lapsing the right if you apply late. Citing one does not cover the other. Article 3(1) of Federal Decree-Law No. 17 of 2025 is a transitional: balances that had already lapsed may be claimed or used against liabilities within one year of 1 January 2026. Tourists claim under the Tax Refunds for Tourists Scheme, which the FTA operates with Planet as exclusive operator. The minimum spend is AED 250, the refund is 87% of the VAT paid (the FTA deducts 13%) less AED 3.60 per tax-free transaction, and the transaction must be validated at the departure port within 90 days of the purchase date. Article 68 of the Executive Regulation defines an overseas tourist as a natural person not resident in any Implementing State and not a crew member on a flight or aircraft leaving an Implementing State, which is why UAE residents cannot use the scheme, whatever the retailer's checkout page suggests.

Foreign businesses with no establishment in the UAE claim under the Business Visitor scheme in Article 67 of the Executive Regulation. The claim period is twelve calendar months, the minimum claim is AED 2,000, and the FTA opens submissions annually from 1 March to 31 August. Reciprocity applies: a business from a country that does not refund VAT to UAE entities in similar circumstances is not entitled to claim, and foreign tour operators are excluded for their tour operating activities. UAE nationals building a home claim under Article 66. A natural person who is a UAE national and builds a residence for use solely by themselves or their family may reclaim the VAT on contractor services and building materials, not on furniture or electrical appliances, and the claim must be lodged within 12 months of the date of completion, meaning the earlier of occupation or certification as complete.

Deregistration is compulsory in two cases under Article 21 of the VAT Law: where the registrant stops making taxable supplies, and where the value of taxable supplies over twelve consecutive months falls below the voluntary registration threshold of AED 187,500 and the registrant does not expect to exceed it. Article 14 of the Executive Regulation requires the application to be made within 20 business days of the triggering event.

A registrant whose taxable supplies over the past twelve months fell below the mandatory threshold of AED 375,000, but who remains above the voluntary threshold, may apply to deregister but is not obliged to. A person who registered voluntarily under Article 17 may not deregister within twelve months of the date of registration.

Deregistration does not close the file. A final return must be filed for the last tax period, output tax must be accounted for on assets on hand where input tax was recovered, and the FTA retains the right to claim due tax and penalties after the registration ends.

The penalty schedule sits in Cabinet Decision No. 40 of 2017 on Administrative Penalties, amended by Cabinet Decision No. 49 of 2021, Cabinet Decision No. 108 of 2021 and, most recently, Cabinet Decision No. 129 of 2025, which was issued on 9 October 2025 and takes effect from 14 April 2026. The 2025 amendment materially changed how late payment and voluntary disclosure penalties are calculated, so any figure quoted from before that date should be treated as stale. The amounts below are as published by the Ministry of Finance in the consolidated text, current at 12 August 2026.

A tax audit is the FTA's inspection of commercial records, information, data or goods to determine whether a person has met their obligations under the Tax Procedures Law and the tax law. It may be conducted at the FTA's offices or at the taxable person's premises, and it usually starts with a notice and a document request rather than an unannounced visit.

Article 46 of Federal Decree-Law No. 28 of 2022 caps the exposure. The FTA may not conduct an audit or issue an assessment more than five years after the end of the relevant tax period. Two extensions matter: where the person was notified that an audit had commenced before the five years expired, the audit must be completed or the assessment issued within four years of that notification; and where the audit relates to a voluntary disclosure filed in the fifth year, the FTA gets one year from the date of that disclosure.

Failing to give the auditor reasonable facilitation attracts AED 20,000, payable from the person's, legal representative's or tax agent's own funds. Records must be kept in a form that lets the FTA verify the return, and must be produced in Arabic on request.

There is no single official "UAE VAT bare act" book, and the PDFs circulating on file-sharing sites are usually outdated consolidations from third parties. The authoritative texts are free, published by the Federal Tax Authority and the Ministry of Finance, and updated as amendments are made. Use those and nothing else for a compliance decision. The FTA legislation page for VAT carries the consolidated Federal Decree-Law No. 8 of 2017 and its amendments, the Executive Regulation with its amendments, the cabinet decisions on designated zones, administrative penalties and the tourist refund scheme, and the FTA's own tax transaction directives. The FTA also publishes topic guides and public clarifications (designated zones, real estate, input tax apportionment and others) which are the closest thing to an official UAE VAT handbook and are more useful than any commercial summary because they state the FTA's own position.

A valid tax invoice stops being enough on 1 October 2026.

Article 54 bis of the VAT Law, inserted by Federal Decree-Law No. 16 of 2025, gave the Federal Tax Authority the power to refuse an input tax deduction where the supply sat in a chain connected to tax evasion and the recipient knew or should have known. That was the power. FTA Decision No. 13 of 2026 — issued 22 July 2026, published 20 August 2026 and effective 1 October 2026 — is the procedure: what a taxable person must actually check, and document, before deducting.

It runs on two axes. Article 3 is about the supplier: who they are, whether their place of business is real and consistent with what they do, whether they trip any of three risk indicators, and — above a threshold — whether they hold a bank account. Article 4 is about the supply: whether the transaction has a genuine commercial reason, whether the payment route makes sense, and whether the goods or services are even within the supplier's licensed activity.

The part that changes daily practice most is Article 5(3) and 5(4). It is not enough to have done the checks. You must document that you did them, retain the supporting records, and keep a written policy naming who is responsible for carrying out, reviewing and supervising the verification. A business that checks carefully and writes nothing down has not complied.

UAE VAT has moved more in the last eighteen months than in the previous five years, and most of the movement is about digitalisation and enforcement rather than rates. The 5% standard rate and both registration thresholds are unchanged. Statement current at 12 August 2026; check the FTA legislation page before relying on any of the following. Cabinet Decision No. 100 of 2025, issued 12 August 2025 and effective 29 September 2025, amended Articles 59 and 60 of the Executive Regulation to accommodate electronic invoicing. Federal Decree-Law No. 16 of 2025 took effect on 1 January 2026 and did four things. Article 48(1) now ends “with the exception of issuing a Tax Invoice to himself”, removing the self-invoice on the reverse charge. Article 74(3) now lapses an excess credit carried forward for more than five years from the end of the tax period in which it arose. A new Article 54 bis lets the FTA reject an input tax deduction where the supply was part of a chain connected to tax evasion and the person was, or should have been, aware of it.

And Article 79 bis, the VAT Law's own statute of limitation, was cancelled, leaving the five-year rule in Article 46 of the Tax Procedures Law to do that work. The five-year cap on applying for a refund is a different instrument again: Article 38 of the Tax Procedures Law, amended by Federal Decree-Law No. 17 of 2025. Cabinet Decision No. 153 of 2025 extended the domestic reverse charge to metal scrap. Cabinet Decision No. 129 of 2025, effective 14 April 2026, replaced the old late-payment penalty formula with a monthly penalty of 14% per annum and restructured the voluntary disclosure penalties. On the horizon, the Ministry of Finance has scheduled the e-invoicing pilot for 1 July 2026, with mandatory implementation for businesses at or above AED 50 million of annual revenue from 1 January 2027 and for everyone else from 1 July 2027. Appointment deadlines for Accredited Service Providers have already been extended once. If your invoicing system is not on the roadmap yet, that is the compliance project to start.

Our page on the 2026 VAT Law amendments works through all four changes, article by article, with the worked examples and the deadlines that the summary above skips.

Whether a supply is zero-rated, exempt or standard-rated decides whether you can recover input tax, so the classification matters as much as the rate. These guides take each sector in turn: healthcare, education, financial services, real estate, transport, charities and more, and the legal basis for each treatment under Federal Decree-Law No. 8 of 2017.

Most VAT questions are answerable from the legislation, and this page is written so that you can answer yours without paying anyone. Where advice earns its fee is in the grey zones: apportionment methods for a partly exempt business, whether a supply is genuinely exported, the place of supply for cross-border services, the treatment of a designated zone transaction, and how to disclose a historic error without turning a AED 20,000 problem into a AED 200,000 one. If that is where you are, the useful next step is a review of what has actually been filed against what should have been, before the FTA reaches the same question first. Voluntary disclosure penalties are materially lower than the penalties for errors found on audit, 1% per month, against 15% of the tax difference plus 1% per month where the disclosure was not made before the audit notification. The arithmetic rewards moving first.