E-Invoicing Guidelines by the UAE Ministry of Finance

The UAE Ministry of Finance (‘the MoF’) recently released comprehensive E-invoicing guidelines, underscoring the Government’s dedicated approach to a standardized and timely implementation of new system. The key aspects of the guidelines are summarized below:

E-invoicing Guidelines – Inclusions & Exclusions

Inclusions Exclusions
  • B2B and B2G; G2B and G2G
  • All Business transactions (B2B & B2G) are covered under the E-invoicing system i.e., Taxable transactions, out-of-scope transactions, Exempt transactions, Export transactions regardless of the location of the supplier and buyer
  • Applies to non-resident persons as well who is carrying out business in the UAE
  • Financial Services which are taxable at standard rates
  • B2C, G2C, C2C
  • Government entities conducting transactions in a sovereign capacity
  • Financial services exempt under the VAT Law included export of exempted financial service
  • Passenger transportation service by Airline with Electronic ticket
  • Investment Holding Companies having passive income only (e.g., dividend income)

Temporary Grace Period

A temporary grace period of 24 months from 1 January 2027 has been granted to implement the e-invoicing regulations with respect to the following transactions:

  • Transactions between the companies under the same VAT Group
  • International transportation of goods by an Airline, where Airway bill is issued

Type of Invoices and Tax Codes

Type of Document Nature of transactions
Electronic Tax Invoice and Electronic Tax Credit Note Eg: Standard Rated Sales, Export Sales (including self-billing arrangements)
Commercial Invoice and Electronic Credit Note Eg: Out of Scope supplies, exempt supplies, supplies by VAT unregistered businesses etc.

Use of Peppol ID

Peppol ID Nature of transactions
235+10-digit TIN For all businesses registered for e-invoicing
Businesses conducting transactions under the purview of E-Invoicing, but not registered for any tax, must register with the FTA to obtain a TIN
0235:9900000098 Transactions where the buyer is not registered under of E-invoicing system
For the Buyer who is not in scope of E-invoicing, the predefined Peppol ID will be used, but a human-readable invoice will be issued to recover input tax credit on the same
0235: 9900000099 Transactions where the buyer is overseas and does not have a Peppol ID
0235: 9900000097 Transactions classified as Deemed Supply

Other Key Aspects

  • A detailed guide has been issued on Invoice data fields (mandatory fields with clarification of each fields)
  • Key requirement is the Invoice Transaction Type Code, which needs the issuers to explicitly flag include transaction involving Freezone, Deemed supply, Margin Scheme, Summary Invoice, Continuous Supply, Disclosed Agent billing, Supply through E-commerce and Exports
  • For a retail business that only carries out B2C, E-invoicing shall (currently) not apply. If the business has both B2B and B2C transactions, E-invoicing applies to the B2B part
  • E-Invoicing framework is designed to support both the Arabic and English languages. Whilst Arabic is not mandatory, the FTA has the mandate to request a translation in Arabic of any Tax Records
  • A separate Tax Invoice or commercial invoice (i.e., one that is not e-invoice) may be required by the buyers which have not yet implemented e-invoicing to support recovery of input tax credit, corporate income tax deductions, etc.
  • E-invoicing data can be stored outside UAE provided it is readily made available whenever required.

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