The UAE Federal Tax Authority has issued VAT Public Clarification VATP045 for Concerned Goods, Accounting for Output Tax, Issuing Tax Invoices, and Input Tax Recovery. The clarification addresses an important historical VAT compliance issue for UAE businesses that imported goods on or before 31 December 2025. Most importantly, the FTA clarifies that where certain supporting documents and VAT return requirements are satisfied, an importer may not need to have issued a Tax Invoice to itself in respect of those historical imports. It also confirms that the absence of such a self-issued Tax Invoice does not, by itself, necessarily prevent recovery of the related Input VAT.
What are “Concerned Goods”?
For purposes of the clarification, Concerned Goods broadly include goods imported into the UAE that would not have been exempt from VAT if supplied within the UAE.
Examples given by the FTA include spare parts, machinery and other goods imported into the UAE.
Under the VAT rules applicable before 1 January 2026, a taxable person importing Concerned Goods for its business was regarded as making a taxable supply to itself and was responsible for accounting for the related VAT.
Important change from 1 January 2026
The first point businesses should understand is that VATP045 primarily deals with a historical requirement. The VAT Law was amended with effect from 1 January 2026, and taxable persons are no longer required to issue Tax Invoices to themselves when importing Concerned Goods. Accordingly, VATP045 expressly applies to Concerned Goods imported on or before 31 December 2025.
What was the historical issue?
For imports made before 1 January 2026, a VAT-registered importer was required to account for Output Tax and, under the legislation then applicable, issue a Tax Invoice to itself in respect of the import, unless an administrative exception had been obtained from the FTA.
In practice, businesses may have correctly:
- imported the goods
- accounted for the import VAT
- retained the foreign supplier's invoice
- retained Customs documentation
- retained Customs documentation
but not prepared a separate Tax Invoice to themselves. VATP045 provides important clarification for such cases.
FTA provides practical relief from the self-invoice requirement
Considering the administrative burden involved, the FTA accepts that a recipient of Concerned Goods is not required to issue the Tax Invoice to itself where the recipient:
1. Retains the overseas supplier's invoice
The invoice should contain details of the Concerned Goods and the consideration paid.
2. Retains the relevant Customs declaration
The declaration should be issued by the relevant Emirate Customs Department and reflect the details and value of the Concerned Goods.
3. Correctly accounts for the VAT in the VAT Return
The business should verify that the correct VAT amount has been prepopulated in Box 6 or make the necessary adjustment through Box 7.
Where all these requirements are satisfied, the FTA states that the recipient does not need to separately apply for an administrative exception from the Tax Invoice requirement.
What if the business did not issue a self-invoice but claimed Input VAT?
This is perhaps the most important clarification.
The FTA confirms that a recipient can still be eligible to recover the related Input VAT even where it did not issue a Tax Invoice to itself, provided it retains:
- the invoice issued by the overseas supplier; and
- the declaration issued by the relevant Emirate Customs Department.
The normal Input VAT recovery conditions must, of course, still be satisfied. The Concerned Goods must be used, or intended to be used, for making taxable supplies, and the relevant supporting documents must be obtained and retained. This clarification may therefore be particularly important for businesses reviewing historical import transactions where the underlying VAT was correctly accounted for but the self-invoice documentation was not prepared.
Don't simply accept Box 6 – reconcile it
VATP045 also reinforces an important VAT return control. The value of imported goods and related Output VAT prepopulated in Box 6 should be reconciled against the business’s own records for the relevant Tax Period. Where there is a discrepancy in the prepopulated figures, or another person has imported goods on behalf of the taxable person, the appropriate adjustment should be made in Box 7. Therefore, businesses should not treat the prepopulated import figures in the VAT return as automatically correct.
When can the Input VAT be recovered?
The clarification also addresses the timing of Input VAT recovery. The Registrant may recover Input VAT in the first Tax Period, or the immediately following Tax Period, in which it:
- obtains the relevant supporting documentation; and
- satisfies the payment requirement.
For this purpose, the recipient is regarded as having paid the consideration where it has paid, or intends to pay, within six months from the agreed payment date.
What should businesses review now?
Businesses with material imports made up to 31 December 2025 should consider reviewing historical import documentation, particularly where self-issued Tax Invoices were not prepared. A practical reconciliation could be:
& VAT
Box 6 / Box 7
Recovered
Where the business has the overseas supplier invoice and Customs declaration and has correctly dealt with the VAT through the VAT return, VATP045 provides important clarification regarding the historical self-invoicing requirement. However, the FTA specifically states that the relief described in the clarification does not apply where the recipient has not obtained the overseas supplier invoice or the relevant Customs declaration.
Conclusion
For Concerned Goods imported on or before 31 December 2025, not issuing a Tax Invoice to yourself does not necessarily mean that Input VAT recovery is lost.
VATP045 provides welcome clarity for businesses that imported goods into the UAE before 2026. For Concerned Goods imported on or before 31 December 2025, not issuing a Tax Invoice to yourself does not necessarily mean that Input VAT recovery is lost. Where the required foreign supplier invoice and Customs declaration are retained and the correct VAT has been reflected through Box 6 or adjusted through Box 7, the FTA accepts that the recipient does not need to issue the self-invoice or separately apply for the administrative exception, subject to the conditions explained in VATP045.
For imports from 1 January 2026 onwards, the law has changed and taxable persons are no longer required to issue Tax Invoices to themselves when importing Concerned Goods.
RVG Chartered Accountants can assist businesses in reviewing historical import VAT positions, Customs-to-VAT reconciliations and Input VAT recovery documentation.
