When must a tax invoice be issued?

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.

Article 59 – Tax invoices 43,44 1. A Tax Invoice shall contain all of the following particulars: a. The words “Tax Invoice” clearly displayed on the invoice. b. The name, address, and Tax Registration Number of the Registrant making the supply. c. The name, address, and Tax Registration Number of the Recipient where he is a Registrant. d. A sequential Tax Invoice number or a unique number which enables identification of the Tax Invoice and the order of the Tax Invoice in any sequence of invoices. e. The date of issuing the Tax Invoice. f. The date of supply if different from the date the Tax Invoice was issued. g. A description of the Goods or Services supplied. h. For each Good or Service, the unit price, the quantity or volume supplied, the rate of Tax and the amount payable expressed in AED. i. The amount of any discount offered. j. The gross amount payable expressed in AED. k. The Tax amount charged under the provisions of the Decree-Law expressed in AED, together with the rate of exchange applied where the currency is converted from a currency other than the UAE dirham. l. Where the invoice relates to a supply under which the Recipient of Goods or Recipient of Services is required to account for Tax, a statement that the Recipient is required to account for Tax, and a reference to the relevant provision of the Decree-Law. 43 Article amended as per Cabinet Decision No. 100 of 2024. 44 Article amended as per Cabinet Decision No. 100 of 2025. Cabinet Decision No. 52 of 2017 and its amendments – As published by the Ministry of Finance 51 2. A simplified Tax Invoice shall contain all of the following particulars: a. The words “Tax Invoice” clearly displayed on the invoice. b. The name, address, and Tax Registration Number of the Registrant making the supply. c. The date of issuing the Tax Invoice. d. A description of the Goods or Services supplied. e. The total Consideration and the Tax amount charged expressed in AED. 3. If there are or will be sufficient records available to establish the particulars of a supply, a Registrant is not required to issue a Tax Invoice for the supply where the supply is a wholly zero-rated supply. 4. Where a Registrant is required to issue a Tax Invoice, the Tax Invoice must meet the requirements of Clause 1 of this Article. 5. As an exception to Clause 4 of this Article, and in cases other than where the reverse charge mechanism applies in accordance with Article 48 of the Decree-Law, the Registrant may issue a simplified Tax Invoice that meets the requirements of Clause 2 of this Article in either of the following two situations: a. Where the Recipient of Goods or Recipient of Services is not a Registrant. b. Where the Recipient of Goods or Recipient of Services is a Registrant and the Consideration for the supply does not exceed AED 10,000 (ten thousand dirhams). 6. A Registrant shall not issue separate Tax Invoices in respect of supplies where he makes more than one supply of Goods or Services to the same Person and those supplies are included on a summary Tax Invoice issued and delivered to the Recipient of Goods or Recipient of Services. 7. Where the Authority considers that there are or will be sufficient records available to establish the particulars of any supply or class of supplies, and that it would be impractical to require that a Tax Invoice be issued by the Registrant, the Authority may determine that, subject to any conditions that the Authority may consider necessary: a. Any of the particulars specified in Clauses 1 or 2 of this Article shall not be contained in a Tax Invoice. b. A Tax Invoice is not required to be issued or delivered in certain cases. 8. The Registrant may issue a Tax Invoice by electronic means provided that: a. the Registrant must be capable of securely storing a copy of the Tax Invoice in compliance with the record keeping requirements. b. the authenticity of origin and integrity of content of the Tax Invoice should be guaranteed. Cabinet Decision No. 52 of 2017 and its amendments – As published by the Ministry of Finance 52 9. Where a Recipient agrees to raise a Tax Invoice on behalf of a Registrant Supplier in respect of a supply of Goods or Services, that document shall be treated as if it had been issued by the supplier if the following conditions are met: a. The Recipient of the Goods or Services is a Registrant. b. The supplier and the Recipient agree in writing that the supplier shall not issue a Tax Invoice in respect of any supply to which this Clause applies. c. The Tax Invoice shall contain the particulars required under Clause 1 of this Article. d. The words “Tax Invoice raised by buyer” are clearly displayed on the Tax Invoice. 10. Where a Tax Invoice is issued pursuant to Clause 9 of this Article, any invoice issued by the Supplier in respect of that supply shall be deemed not to be a Tax Invoice. 11. Where an agent who is a Registrant makes a supply of Goods or Services for and on behalf of the principal of that agent, that agent may issue a Tax Invoice in relation to that supply as if that agent had made the supply, provided that the principal shall not issue a Tax Invoice, subject to: a. the agent retaining sufficient records in such a manner as to determine the name, address and Tax Registration Number of the principal supplier, and b. the principal supplier retaining sufficient records in such a manner as to determine the name, address and Tax Registration Number of the agent. 12. Where the Supply of Goods or Services is considered as supplied in an Implementing State, the Registrant must include the following additional particulars in the document issued: a. the tax registration number of the Recipient of Goods or Recipient of Services issued to him by the competent authority of the Implementing State in which the supply is treated as taking place, b. a statement identifying the supply as between a supplier in the State and a Recipient of Goods or Recipient of Services in an Implementing State, and c. any other information specified by the Authority. 13. For the purposes of Clause 2 of Article 67 of the Decree-Law, the Registrant shall issue the Tax Invoice within 14 (fourteen) days from the date of the supply provided for in Article 25 or 26 of the Decree-Law, except in the following cases: a. where the Tax Invoice is issued in accordance with Clause 2 of this Article, the Registrant shall issue the Tax Invoice on the date of supply, b. for the purposes of Clause 6 of this Article, the Registrant shall issue a summary of the Tax Invoice and deliver it to the Recipient of Goods or Recipient of Cabinet Decision No. 52 of 2017 and its amendments – As published by the Ministry of Finance 53 Services within 14 (fourteen) days of the end of the calendar month within which the date of supply occurs for such supplies. c. any other cases specified by the Authority. 14. Where the Authority grants approval under Clause 7 of this Article, such approval may be withdrawn at any time where the Authority considers that the conditions of approval are no longer met. 15. As an exception to Clause 5 of this Article, the Authority may specify the cases in which a Tax Invoice that meets the requirements of Clause 1 of this Article must be issued, even if one of the cases provided for in Clause 5 of this Article applies. 16. Where a Registrant is required to issue a Tax Invoice in the form of an Electronic Invoice pursuant to Clause 5 of Article 65 of the Decree-Law or where the Registrant issues a Tax Invoice in the form of an Electronic Invoice on a voluntary basis, Clauses 2, 3, 5, 7, 8, 15 of this Article and any other Clause as determined in a decision issued by the Minister shall not apply.

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

from the principal supplier to the undisclosed agent, and a supply from the undisclosed agent to the recipient of the supply. In effect, the undisclosed agent is treated as both the buyer and the seller of the goods or services. The simultaneous supplies means that both the principal supplier and the undisclosed agent must separately charge VAT applicable on the supply of the underlying goods or services, and must account for this VAT to the FTA in their own VAT returns. Where it is eligible under the general input tax recovery rules, the undisclosed agent may also recover the VAT which was charged to it by the principal supplier – this ensures that this VAT is not a cost to the agent. VAT treatment of agency services As discussed in Part 5.3.1, where an undisclosed agent and the principal agree that the agent can charge a separate agency fee or commission for the agency services to the principal, the agent must consider the VAT treatment of this services separately from the VAT treatment of the underlying supply of goods or services. On the other hand, where the agent is able to embed the fee as a mark-up to the sale price of the goods or services, then the VAT treatment of the agency services should follow the VAT treatment of the underlying goods or services. 5.4. Tax invoice requirements As a default rule, a VAT-registered supplier of a taxable supply of goods or services is required to issue an original tax invoice and deliver it to the recipient of the supply.34 This condition applies irrespective of whether the goods are sold directly or through an electronic marketplace. As an exception to the default rule, where a VAT-registered agent makes a supply of goods or services on behalf of a principal, the agent may issue a tax invoice in relation to that supply as if that agent had made the supply.35 A tax invoice issued by the agent must contain all the usual particulars required under Article 59 of the Executive Regulation, but may include the agent’s, rather than the supplier’s, details – in which case, the invoice should, however, contain a reference to the principal supplier (including the supplier’s name and TRN) somewhere on the invoice. Only one tax invoice may be issued for any supply of goods or services. Therefore, this option is not available where the principal supplier has already issued a tax invoice. Similarly, where an agent has issued a tax invoice in respect of a supply made by the principal, the agent must ensure that the principal receives a copy of that tax invoice, and the principal should not issue its own tax invoice in respect of the same supply. It is important to note that where the invoice is issued by the agent, the supply is still treated as being made by the principal supplier to the recipient of the supply. As a 34 35 Article 65(1) of the Decree-Law. Article 59(11) of the Executive Regulation. 28