What the FTA’s Public Clarification VATP045 means for imports made on or before 31 December 2025

The UAE Federal Tax Authority has issued Public Clarification VATP045, addressing how businesses that import “Concerned Goods” from outside the UAE should account for VAT, issue tax invoices, and recover input tax. While the underlying rule is not new, this clarification is especially relevant right now because of a key transitional detail: as of 1 January 2026, the self-invoicing requirement it describes has been removed. That means VATP045 only applies looking backward to imports made on or before 31 December 2025 which makes it essential reading for anyone finalising 2025 VAT positions or preparing for an FTA audit.

What Are “Concerned Goods”?

Concerned Goods are goods imported into the UAE that would not have been exempt from VAT had they been supplied locally think spare parts, machinery, and similar imported items. Under Article 48(1) of the VAT Law, importing such goods for business purposes is treated as if the Taxable Person made a taxable supply to itself, triggering an obligation to account for Output Tax.

The Core Rule (Pre-2026 Imports)

A Registrant importing Concerned Goods before 1 January 2026 was required to: account for Output Tax on the import, and issue itself a valid Tax Invoice within 14 days unless it had obtained an administrative exception from the FTA under Article 59(7)(b) of the Executive Regulation.

A Practical Way Out of Self-Invoicing

Recognising the administrative burden of issuing invoices to oneself, the FTA confirms that a Recipient does not need to apply for a formal exception if it simply: keeps the overseas supplier’s invoice (showing the goods and consideration paid), keeps a declaration from the relevant Emirate Customs Department (showing details and value), and ensures the correct VAT is reflected in Box 6 of the VAT return — or adjusted in Box 7 if there’s a discrepancy. Meeting these three conditions is enough; no separate application is required.

Input Tax Recovery Doesn’t Depend on Self-Invoicing

Perhaps the most useful takeaway: a Recipient can still recover the related Input Tax even if it never issued itself a Tax Invoice as long as it retains the overseas supplier’s invoice and the customs declaration, and the goods were used (or intended to be used) to make taxable supplies. Recovery can be claimed in the first Tax Period in which the supporting documents were obtained and the consideration was paid and consideration is treated as paid if it is paid, or intended to be paid, within six months of the agreed payment date.

Tax Credit Notes and Return Reconciliation

If a Registrant did issue itself a Tax Invoice for Concerned Goods, it must also issue itself a Tax Credit Note whenever there is a later adjustment to those goods. Separately, businesses should reconcile the value of imported goods and the related Output Tax pre-populated in Box 6 of the VAT return against internal records, making any needed correction in Box 7 — including where an agent imported goods on the Taxable Person’s behalf.

Why This Matters Right Now

• VATP045 is backward-looking: it only applies to Concerned Goods imported on or before 31 December 2025 — from 1 January 2026, the self-invoicing requirement no longer applies.
• If you’re closing out 2025 VAT positions, confirm you hold both the overseas invoice and the customs declaration for any imported Concerned Goods.
• Don’t assume a missing self-invoice blocks your Input Tax recovery — it doesn’t, provided the right supporting documents are in place.
• Review Box 6 and Box 7 entries on 2025 VAT returns for accuracy, especially where goods were imported through an agent.

In short, VATP045 offers welcome practical relief for the pre-2026 period: businesses that kept proper supplier invoices and customs declarations were never at real risk of losing their Input Tax recovery, even without a self-issued Tax Invoice. As always, the safest approach is to document the paper trail properly and keep it on file.