UAE MOVES TOWARDS A MORE COMPLIANCE-FOCUSED TAX LANDSCAPE WITH RECENT VAT REFORMS: DHRUVA

Dhruva, a premier tax advisory firm with deep expertise across the Middle East, India, and Asia, stated that the UAE’s latest amendments to the VAT Law and the Tax Procedures Law, issued by the Federal Tax Authority (FTA) which are effective from 1 January 2026, represent a significant shift toward a more structured, and risk-focused tax environment. These amendments are expected to reinforce responsible compliance behaviors and reduce administrative friction for UAE businesses.

Dhruva noted that one of the most practical and welcoming changes is that it eliminates the requirement for taxpayers to self-issue tax invoices for imports subject to the reverse charge mechanism, which provides a lot of ease to businesses. Post series of amendments and clarifications issued by the FTA in 2025 in relation to self-issuance of tax invoices for imports, while a general exception was granted for such requirement for import of services, the same were required in case of import of goods for record-keeping purposes.  This often-added administrative complexity without impacting the actual tax liability or input tax entitlement. Under the updated rules, taxable businesses have removed the obligation entirely, and hence, businesses will only need to maintain standard supporting documentation, such as invoices, contracts, and transaction records.

However, the firm highlighted that while some administrative burdens are being eased, compliance expectations are tightening elsewhere.  One of the amendments gives the FTA authority to deny input tax recovery in cases linked to tax evasion – where a taxpayer knew or, critically, should have known, that a supply or its broader supply chain was connected to tax evasion.  The law clarifies that taxpayers will be deemed to have been aware if they fail to verify the validity and integrity of the supply in accordance with procedures to be issued by the FTA.

Dhruva explained that historically, the responsibility to account for VAT rested primarily with the supplier, and recipients focused mainly on validating the tax invoice and meeting standard input-tax recovery conditions. In practice, however, the FTA has often linked a recipient’s input-tax eligibility to the supplier’s discharge of output VAT, denying recovery where gaps existed. The latest amendment now formally embeds this position in law, imposing additional due-diligence obligations on the recipient.

Ujjwal Pawra, Partner at Dhruva Consultants, commented, “This is a significant change. It is a clear message that the right to input tax recovery comes with the responsibility to validate the integrity of one’s suppliers and supply chain. Businesses must now demonstrate that they exercised practical, documented, and consistent due diligence. Clean invoices alone are no longer enough; what matters is a clean process.”

While the procedures and conditions are awaited, Dhruva advised that companies reassess onboarding procedures, supplier-vetting protocols, and documentation trails to ensure they align with the FTA’s expected standards. 

Another material operational change is the introduction of a defined timeframe to act on credit balances. Under the amended framework, businesses will generally have up to five years from the end of the relevant tax period to request a refund of a credit balance or use that balance to settle tax liabilities, with targeted flexibility in specified cases where credits arise late in the cycle.

Transitional relief is also available for certain older credits around the changeover, which can help businesses address legacy positions in an orderly way. Dhruva said these changes reduce the risk of credits remaining unresolved on the balance sheet, improve cash flow planning, and encourage clearer internal ownership of refund positions.

Ujjwal further added, “The UAE has introduced a more robust operating framework for credit balances and refunds in line with international best practices. The message is simple: know your credits, map the deadlines, and file claims that are clear, complete, consistent, and easy to validate.”

Dhruva advised UAE businesses to act now with a finance-led approach. This starts with building a central credit-balance register by tax type and tax period, assigning an accountable owner, and tracking action dates so credits are either utilised or claimed in time. Businesses should also treat refund submissions as audit-ready files by preparing reconciliations, supporting documents, and a concise explanation of how the credit arose and why the amount is correct before submitting, rather than rebuilding the file after queries begin. In parallel, companies should prioritise older credit positions to assess whether they fall within the transitional relief window and avoid last-minute filings.

The firm also advised businesses to monitor any binding directions issued by the FTA and align their tax positions, documentation, and system settings accordingly to minimize interpretational differences and strengthen consistency over time.