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Our approach
One framework, one transaction
The UAE VAT Law is a single framework. A domestic sale, an export and an import are not separate regimes; they are the same law applied to different facts. That is why we look at each transaction as a whole, from the first commercial terms through to how it is reported and recovered.
Reviewing a transaction end to end shows where the VAT treatment is decided, where it can go wrong, and how one decision early on (a contract clause, a delivery term, a location) carries through to the invoice and the return.
- StartContract and pricingWho supplies what to whom, and is the price VAT inclusive?
- ThenSupplyWhat is the place, time and nature of supply?
- ThenInvoicingIs the tax invoice or credit note compliant and issued on time?
- ThenPayment and recoveryIs output tax paid and input tax recoverable?
- EndReporting and recordsIs it reported correctly and supported by records?
Every transaction moves through the same stages, whether it stays in the UAE or crosses a border.
Considerations
General and special considerations
Within that single framework, some rules apply to every transaction and others apply only when particular facts are present.
Rules that apply to every taxable transaction.
- Whether the activity is a supply of goods or services, and its VAT treatment
- Place of supply and date of supply
- Value of supply, including discounts and consideration in kind
- Tax invoices, credit notes and record keeping
- Input tax recovery and apportionment
- Return preparation inputs, adjustments and corrections
Rules triggered by the facts of a particular transaction.
- Exports of goods and services, and the evidence needed to zero-rate them
- Imports of goods and services, including the reverse charge mechanism
- Supplies involving designated zones
- Zero-rated and exempt supplies, such as certain real estate, financial and healthcare supplies
- Tax groups, transfers of a business and related party supplies
- Sector-specific rules, for example real estate, construction and the profit margin scheme
Applicability, penalties and our services
Who VAT applies to, what is at stake and how we help
Whether VAT applies to you determines your obligations, your obligations determine your exposure to penalties, and both shape the support you need.
Applicability
Who needs to consider VAT
Mandatory registration
Businesses whose taxable supplies and imports exceeded AED 375,000 in the previous 12 months, or are expected to exceed it in the next 30 days.
Voluntary registration
Businesses whose taxable supplies, imports or taxable expenses exceed AED 187,500.
Non-resident businesses
Those making taxable supplies in the UAE where no other person is required to account for the VAT.
Importers
Businesses importing goods or services that must account for VAT under the reverse charge mechanism.
Businesses in designated zones
Companies operating in or trading with designated zones, where specific rules apply.
Related businesses
Entities that may register together as a tax group.
Penalties
What non-compliance can cost
Administrative penalties apply under the Tax Procedures Law and the related Cabinet Decisions. Common triggers include:
- Not registering, or registering late
- Filing VAT returns late
- Paying VAT late
- Submitting incorrect returns, or not correcting errors through a voluntary disclosure
- Not issuing compliant tax invoices or credit notes
- Not keeping the required records, or not providing them to the FTA when requested
Penalty amounts are set by Cabinet Decision and are revised from time to time. We confirm the rules in force when we review your position.
Our services
How we help
- VAT registration, tax group and deregistration support
- Transaction reviews from contract to return
- VAT health checks and compliance reviews
- Review of VAT returns before submission
- Advice on exports, imports and designated zone transactions
- VAT impact assessments for new business models and contracts
- Support with voluntary disclosures and error correction
- Help preparing for FTA audits and information requests
- Refund claim support
- VAT training for finance and commercial teams
Why RSM
Why choose RSM
Hands-on VAT compliance experience
We review your VAT returns before they are filed and assist your team with ongoing compliance, including preparing for FTA queries. Filing returns and corresponding with the FTA remain the responsibility of your management, and we support you at each step so those submissions are accurate and well supported.
Current with the VAT Law and FTA guidance
The VAT Law, its Executive Regulations and FTA guidance continue to evolve. We track each change and apply it to your transactions, so your VAT position reflects the rules as they stand.
The whole transaction, not one part of it
Because we look at a transaction from start to finish, we catch issues that a review limited to returns or invoices can miss.
Part of a global network
For cross-border transactions, we work with RSM colleagues in other jurisdictions to understand both sides of the supply.
Contact
Talk to our VAT team
Whether you are reviewing a single contract or your full VAT position, our team can help you look at it from start to finish.
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This page is for general information only and does not constitute tax advice. Specific advice should be obtained for your circumstances before acting on any of the matters discussed.
