Do I still need paper tax invoices after e-invoicing starts?
No. Once e-invoicing starts, electronic tax invoices take the place of paper ones for suppliers in the e-invoicing system. Keep your records (in electronic form) for 7 years so they are readable and available to the FTA on request.
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The detail
No. A Registrant subject to the Electronic Invoicing System must issue and transmit tax invoices as electronic invoices (Art. 65(5), VAT Decree-Law), and nothing in the law, or in FTA guidance, requires you to keep paper copies as well. Record keeping can be fully electronic: records must be retained for 7 years after the end of the relevant Tax Period and be readable and available to the FTA (Art. 56, Corporate Tax Law; Taxable Person Guide confirms invoices may be paper or electronic). If you are not yet within the e-invoicing system, the general tax invoice rules continue to apply.123
What the law says
- A Registrant subject to the Electronic Invoicing System must issue and transmit tax invoices as electronic invoices (Art. 65(5), Federal Decree-Law No. 8 of 2017 as amended).2
- All Taxable and Exempt Persons must maintain records for 7 years following the end of the Tax Period to which they relate, to support tax returns and ascertain taxable income (Art. 56, Federal Decree-Law No. 47 of 2022).1
- FTA guidance: a tax invoice may be a paper or electronic document, and no tax invoice is required for 0% supplies where sufficient records exist (Taxable Person Guide, VATG001, section 12.2).3 Based on FTA guidance
What it depends on
- The electronic-invoice requirement applies only to a Registrant subject to the Electronic Invoicing System; its rollout is phased by FTA determination.2
- Whatever the storage medium, records must be readable, easily accessible, and retainable for the full 7-year period.14
- A valid electronic invoice remains the primary evidence for the customer's input tax recovery, so it must contain all required invoice data.3 Based on FTA guidance
Check before you rely on it
- Confirm whether your business is in the FTA's e-invoicing rollout timetable.
- Make sure your electronic invoices contain all the data required by the VAT Executive Regulation.
- Check your record-keeping system can produce readable records on FTA request for 7 years.
Sources (4) — read the official text
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Article 56 – Record Keeping
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Article 56 – Record Keeping 1. Notwithstanding the provisions of the Tax Procedures Law, a Taxable Person shall maintain all records and documents for a period of (7) seven years following the end of the Tax Period to which they relate that: a. Support the information to be provided in a Tax Return or in any other document to be filed with the Authority. b. Enable the Taxable Person’s Taxable Income to be readily ascertained by the Authority. 2. Notwithstanding the provisions of the Tax Procedures Law, an Exempt Person shall maintain all records that enable the Exempt Person’s status to be readily ascertained by the Authority for a period of (7) seven years following the end of the Tax Period to which they relate.
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Article 65 - Conditions and Requirements for Issuing Tax
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Article 65 - Conditions and Requirements for Issuing Tax Invoices28 29 1. A Registrant making a Taxable Supply shall issue an original Tax Invoice and deliver it to the Recipient of Goods or Recipient of Services. 2. A Registrant making a Deemed Supply shall issue an original Tax Invoice and deliver it to a Recipient of Goods or Recipient of Services if available or keep it in his records if there is no Recipient of Goods or Recipient of Services. 3. The Executive Regulation of this Decree-Law shall specify all of the following: a. Data to be included in the Tax Invoice. b. The conditions and procedures required to issue a Tax Invoice by electronic means. c. Instances where the Registrant is not required to issue and deliver a Tax Invoice to the Recipient of Goods or the Recipient of Services. d. Instances where other documents may be issued in place of the Tax Invoice as well as the conditions thereof and the data to be included therein. e. Instances where a Person may issue a Tax Invoice on behalf of the registered 28 Article amended as per Federal Decree-Law No. 18 of 2022. 29 Article amended as per Federal Decree-Law No. 16 of 2024. Federal Decree-Law No. 8 of 2017 and its amendments – As published by the Ministry of Finance 32 supplier. 4. Any Person receiving an amount as Tax or issuing a Tax Invoice in respect of an amount, must pay such amount to the Authority, and this amount shall be regarded as being similar to Due Tax under the provisions of this Decree-Law. 5. For the purpose of this Article, the Registrant subject to the Electronic Invoicing System must issue and transmit Tax Invoices in the form of an Electronic Invoice, in accordance with the Electronic Invoicing System.
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12. Tax invoices 12.1. Chapter summary The purpose of this chapter is to outline the guidance surrounding the requirement to issue a tax invoice. A tax invoice is a written paper or electronic document which records the details of a taxable supply which has been made. The issue of a valid tax invoice is important for suppliers as it may be used to dictate the date of supply, and therefore determines the tax period in which the output tax should be accounted for. For further information on the date of supply please refer to Chapter 8. The receipt of a valid tax invoice is important for recipients of supplies as it is the primary documentary evidence used to support the recovery of VAT incurred as input tax. For further information on input tax recovery please refer to Chapter 10. 12.2. Requirement to issue a tax invoice 12.2.1. When must a tax invoice be issued? A VAT registered person must issue a tax invoice (also known as “VAT invoice”) and deliver it to the recipient when it makes a taxable supply of goods or services. Furthermore, a VAT registered person making a deemed supply must issue a tax invoice and either deliver it to the recipient (if there is a recipient) or retain it as part of their records (if there is no recipient). There are a number of situations when a tax invoice is not required to be issued: When the supply is subject to VAT at 0% and there are or will be sufficient records available to establish the particulars of the supply. Subject to conditions that may be imposed by the FTA, where the FTA has determined that it would be impractical to require a tax invoice to be issued by the taxable person. It should be noted that exempt supplies and supplies that are not subject to UAE VAT are not considered taxable supplies, and therefore do not require a tax invoice. A person making a supply to another GCC Implementing State where the place of supply is in that state must, however, issue a document which contains most requirements of the tax invoice (please refer to section 12.3 of this Chapter). 45 VAT Guide | Taxable Person | VATG001
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Small Business Relief works by treating eligible Resident Persons as having no Taxable Income if their Revenue is equal to or below AED 3,000,000 for the relevant Tax Period and all previous Tax Periods. Therefore, in order to demonstrate that they have no Taxable Income, the eligible Resident Persons must be able to provide evidence to the FTA that their Revenue did not exceed the Small Business Relief threshold for all relevant Tax Periods. As every Business is different, there is no prescribed list of documentation or records that should be maintained. However, examples of documents which need to be kept include but is not limited to: ● ● ● ● ● Bank statements; Sales ledgers; Invoices or other records of daily earnings, such as till rolls; Order records and delivery notes; and Other relevant Business correspondence. There is no requirement that documents are maintained in their original format and it may be possible to keep them in an alternative format. For example, paper receipts could be scanned and stored electronically. Whatever storage medium is chosen, the records need to be readable and available to the FTA on request. Businesses are responsible for the storage of their own records and documentation. Taxable Persons must provide the FTA with any information, documents or records reasonably required by the FTA when requested to do so. The records must, therefore, be easily accessible if the FTA requests them. Record keeping period All Businesses must keep records and documents for seven years following the end of the Tax Period to which they relate.63 This requirement applies to the Tax Period to which the documents relate, and not the Tax Period in which they were created. For example, if a Taxable Person uses the cash basis accounting method, they may have invoices which were raised in the Tax Period before the one in which they were paid. In this instance the seven-year period starts from the end of the Tax Period in which the invoices were paid, and not the date that they were created. 63 Article 56 of the Corporate Tax Law. Corporate Tax Guide | Small Business Relief | CTGSBR1 38
Written by AI from the FTA sources above and checked before display. Not tax advice or official FTA information - confirm with a tax adviser before you act. Full disclaimer
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