Here are your most important VAT questions, answered

  DUBAI - President His Highness Sheikh Khalifa bin Zayed Al Nahyan has issued a federal decree for value added tax (VAT). VAT will be implemented in the UAE beginning on January 1, 2018. The rate has been set at 5 percent, which the UAE said is "one of the lowest rates in the world". There are still a lot of questions surrounding VAT and how it is going to be implemented in the UAE. Here's what we know so far from Sheikh Hamdan bin Rashid Al Maktoum, Deputy Ruler of Dubai, UAE Minister of Finance and Chairman of the Federal Tax Authority:

What is VAT?

Value Added Tax is an indirect tax imposed on most supplies of goods and services that are bought and sold. VAT is charged at each step of the ‘supply chain’. Ultimate consumers generally bear the VAT cost while Businesses collect and account for the tax, in a way acting as a tax collector on behalf of the government. A business pays the government the tax that it collects from the customers while it may also receive a refund from the government on tax that it has paid to its suppliers. The net result is that tax receipts to government reflect the ‘value add’ throughout the supply chain.

What is the difference between VAT and Sales Tax?

A sales tax is also a consumption tax, just like VAT. For the general public there may be no observable difference between how the two types of taxes work, but there are some key differences. In many countries, sales taxes are only imposed on transactions involving goods. In addition, sales tax is only imposed on the final sale to the consumer. This contrasts with VAT which is imposed on goods and services and is charged throughout the supply chain, including on the final sale. VAT is also imposed on imports of goods and services so as to ensure that a level playing field is maintained for domestic providers of those same goods and services.

When will the VAT go into effect and what will be the rates?

VAT will be introduced across the UAE on 1 January 2018 at a standard rate of 5%.

Will VAT cover all products and services?

VAT, as a general consumption tax, will apply to the majority of transactions of goods and services unless specifically exempted or excepted by law.

Which categories are VAT exempt?

Exports of goods and services to outside the GCC International transportation of passengers or goods and related supplies Supplies of certain sea, air and land means of transportation (such as aircrafts and ships) Certain investment grade precious metals (e.g. gold, silver, of 99% purity) Newly constructed residential properties, that are supplied for the first time within 3 years of their construction Supply of certain education services, and supply of relevant goods and services Supply of certain Healthcare services, and supply of relevant goods and services Some financial services (life insurance and others clarified in VAT legislation) Residential properties Bare land Local passenger transport Transfer of passengers or goods starting or ending in the UAE or passing through its territory Air transfer of passengers in the UAE on international flights Goods and services related to the supply of the means of transport, which are for operating, repairing, maintaining or converting them Aircrafts or vessels designated for use in the assistance or rescue by air or sea Goods and services related to the transfer of goods or passengers aboard land, air or sea means of transport, designated for consumption on board Anything consumed by means of transportation, any installations or addition thereto or any other uses during transportation. Supply or import of investment-precious metals Residential buildings within (3) years of its completion, either through sale or lease in whole or in part First supply of buildings specifically designed to be used by charities and buildings converted from non-residential to residential Educational services and related goods and services for nurseries, preschool, elementary education, as well as higher educational institutions owned or funded by the Federal or local government, as specified in the Executive Regulation Preventive and basic healthcare services and related goods and services, as specified in the Executive Regulation. Certain financial services as specified in the Executive Regulation Residential (non-zero-rated) buildings either by sale or lease Supply of local passenger transport

How will the government collect VAT?

Businesses will be responsible for carefully documenting their business income and costs and associated VAT charges. Registered businesses and traders will charge VAT to all of their customers at the prevailing rate and incur VAT on goods / services that they buy from suppliers. The difference between these sums is reclaimed or paid to the government.

Will the cost of living increase?

The cost of living is likely to increase slightly, but this will vary depending on the individual’s lifestyle and spending behaviour. If your spending is mainly on those things which are relieved from VAT, you are unlikely to see any significant increase.

What other taxes is the UAE considering?

As per global best practice, the UAE is exploring other tax options as well. However, these are still being analysed and it is unlikely that they will be introduced in the near future. The UAE is not currently considering personal income taxes, however.

What measures will the government take to ensure that businesses don’t use the VAT implementation as an excuse to increase prices?

VAT is intended to help improve the economic base of the country. Therefore, we will include rules that require businesses to be clear about how much VAT you are paying for each transaction. You will have the required information to decide whether to buy something or not.

What will VAT cover?

VAT will be imposed on the import and supply of goods and services at each stage of production and distribution, including what is deemed to be a supply

Where else will VAT be implemented?

VAT will be implemented across all GCC countries over the next two years

When will it be implemented across the GCC?

It will be rolled out in the GCC between January 1, 2018 and January 1, 2019

Why is VAT necessary?

VAT "will bring a new revenue stream for the national economy and GDP. This, in turn, will ensure consistency in the high quality of government services, to mirror the UAE’s advanced position on several global competitiveness indexes,” said Sheikh Hamdan.

Who must register for VAT?

Every person who has a place of residence in the UAE or in a VAT implementing GCC state must register for VAT, if at the end of any month his taxable supplies for the previous 12 months exceeded the mandatory registration threshold or if he expects to exceed the mandatory registration threshold in the next 30 days.

VAT FOR TOURISTS AND VISITORS

Will tourists also pay VAT?

Yes, tourists are a significant source of revenue for the UAE and will pay VAT at the point of sale. Nevertheless, we have set the VAT rate deliberately low so that VAT is a limited burden on all consumers.

Will visiting businesses be able to reclaim VAT?

It is intended that we will allow foreign businesses to recover the VAT they incur when visiting the UAE. This is important as it encourages them to do business and also, because a lot of other countries have VAT systems, it protects the ability of UAE businesses to recover VAT when visiting other countries (where the rates are a lot higher).

VAT FOR NATIONALS, GOVERNMENT ENTITIES AND OTHERS

Can UAE nationals claim VAT?

A scheme will be introduced to allow a UAE national who is not registered for VAT to reclaim VAT paid on goods and services relating to constructing a new residence which will be privately used by the person and his family. This will allow the recovery of VAT on such expenses as contractor’s services and building materials.

How quickly will refunds be released?

Refunds will be made after the receipt of the application and subject to verification checks, with a particular focus on avoiding fraud.

Will non-residents be required to register for VAT?

Non-residents that make taxable supplies in the UAE will be required to register for VAT unless there is any other UAE resident person who is responsible for accounting for VAT on these supplies. This exclusion may apply, for example, where a UAE business is required to account for VAT under a reverse charge mechanism in respect of a purchase from a non-resident.

Will VAT be paid on imports?

VAT is due on the goods and services purchased from abroad. In case the recipient in the State is a registered person with the Federal Tax Authority for VAT purposes, VAT would be due on that import using a reverse charge mechanism. In case the recipient in the State is a non-registered person for VAT purposes, VAT would be paid on import of goods from a place outside the GCC. Such VAT will typically be required to be paid before the goods are released to the person.

How will Government Entities be treated for VAT purposes?

Supplies made by government entities will typically be subject to VAT. This will ensure that government entities are not unfairly advantaged as compared to private businesses. Certain supplies made by government entities will, however, be excluded from the scope of VAT if they are not in competition with the private sector or where the entity is the sole provider of such supplies. It is likely certain government entities will be entitled to VAT refunds – this is designed to avoid budgeting issues and provide a level playing field between outsourced and insourced activities. For the supplies provided for government entities, the treatment of such supplies shall depend on the same supply and not on the recipient of the supply. Therefore, if the supply is subject to the standard tax rate, the treatment would remain the same even if it is provided to a government entity.

Will the goods exempt from customs duties also be exempt from VAT?

Not necessarily. Some goods that are imported may be exempt from customs duties but subject to VAT.

VAT FOR BUSINESSES

Who can or will be able to register for VAT?

A business must register for VAT if their taxable supplies and imports exceed the mandatory registration threshold of Dh375,000. Furthermore, a business may choose to register for VAT voluntarily if their supplies and imports are less than the mandatory registration threshold, but exceed the voluntary registration threshold of Dh187,500. Similarly, a business may register voluntarily if their expenses exceed the voluntary registration threshold. This latter opportunity to register voluntarily is designed to enable start-up businesses with no turnover to register for VAT.

What are the VAT-related responsibilities of businesses?

All businesses in the UAE will need to record their financial transactions and ensure that their financial records are accurate and up to date. Businesses that meet the minimum annual turnover requirement (as evidenced by their financial records) will be required to register for VAT. Businesses that do not think that they should be VAT registered should maintain their financial records in any event, in case we need to establish whether they should be registered. VAT-registered businesses generally: must charge VAT on taxable goods or services they supply; may reclaim any VAT they’ve paid on business-related goods or services; keep a range of business records which will allow the government to check that they have got things right If you’re a VAT-registered business you must report the amount of VAT you’ve charged and the amount of VAT you’ve paid to the government on a regular basis. It will be a formal submission and it is likely that the reporting will be made online. If you’ve charged more VAT than you’ve paid, you have to pay the difference to the government. If you’ve paid more VAT than you’ve charged, you can reclaim the difference.

What does a business need to do to prepare for VAT?

Concerned businesses will have time to prepare before VAT will come into effect in January 2018. During that time, businesses will need to meet requirements to fulfil their tax obligations. Businesses could start now so that they will be ready later. To fully comply with VAT, We believe that businesses may need to make some changes to their core operations, their financial management and book-keeping, their technology, and perhaps even their human resource mix (e.g., accountants and tax advisors). It is essential that businesses try to understand the implications of VAT now and once the legislation is issued make every effort to align their business model to government reporting and compliance requirements. We will provide businesses with guidance on how to fully comply with VAT once the legislation is issued. The final responsibility and accountability to comply with law is on the business.

When are businesses supposed to start registering for VAT?

VAT will come into force on 1 January 2018. Any business that is required to be registered for VAT and charge VAT from 1 January 2018 must be registered prior to that date. To enable businesses to prepare for introduction of VAT and comply with this registration obligation in time, the electronic registrations will be open for VAT from the third quarter of 2017 on a voluntary basis and a compulsory basis from the final quarter of 2017 for those that choose not to register earlier. This will ensure that there is no last minute rush from businesses to register for VAT before the deadline.

When are registered businesses required to file VAT returns?

Taxpayers must file VAT returns with the FTA on a regular basis (quarterly or for a shorter period, should the FTA decide so) within 28 days from the end of the tax period in accordance with the procedures specified in the VAT legislation. The Tax returns shall be filed online using eServices.

What kind of records are businesses required to maintain, and for how long?

Businesses will be required to keep records which will enable the Federal Tax Authority to identify the details of the business activities and review transactions. The specifics regarding the documents which will be required and the time period for keeping them will be stated in the relevant legislation.

How long must a taxable person retain VAT invoices for?

Any taxable person must retain VAT invoices issued and received for a minimum of 5 years.

Will Businesses have to report on their business in each of the Emirates?

It is expected that businesses will need to complete additional information on their VAT returns to report revenues earned in each Emirate. Guidance will be provided to businesses with regards to this. It is expected that the rules will be relatively straightforward for most businesses and will be based, for example, for B2C transactions, on the location of the transaction (e.g. in a retail environment, the location of the shop).

Can two or more businesses apply for tax registration?

Two or more persons conducting business may apply for tax registration as a tax group if all of the following conditions are met: Each person has a place of establishment or fixed establishment in the UAE; the relevant persons are related parties; and one or more persons are conducting business in a partnership that controls the others.

Can businesses have more than one tax registration?

The law prohibits any person conducting business from having more than one tax registration number (TRN) unless otherwise decided by the Executive Regulation.

What about Tax Groups?

If related parties do not apply for Tax Registration as a Tax Group, the Authority may assess their association based on their economic, financial and regulatory practices in business and register them as a Tax Group if the association has been proved according to the controls and conditions specified by the Executive Regulation.

How should a business determine the place of supply?

The place of supply will determine whether a supply is made within the UAE (in which case the UAE VAT law will apply), or outside the UAE for VAT purposes. For a supply of goods, the place of supply should be the location of goods when the supply takes place with special rules for certain categories of supplies (e.g. water and energy, cross border supplies). For the supply of services, the place of supply should be where the supplier is established with special rules for certain categories of supplies (e.g. cross border supplies between businesses).

Can businesses offset customs duty against VAT payments?

VAT shall be payable in addition to the custom duties paid by the importer of the goods and cannot be deducted. VAT shall be computed on the value that includes the customs duties.

How will real estate be treated?

The VAT treatment of real estate will depend on whether it is a commercial or residential property. Supplies (including sales or leases) of commercial properties will be taxable at the standard VAT rate (i.e 5%). On the other hand, supplies of residential properties will generally be exempt from VAT. This will ensure that VAT would not constitute an irrecoverable cost to persons who buy their own properties. In order to ensure that real estate developers can recover VAT on construction of residential properties, the first supply of residential properties within 3 years from their completion will be zero-rated.

Will there be VAT grouping?

Businesses that satisfy certain requirements covered under the Legislation (such as being resident in the UAE and being related/associated parties) will be able to register as a VAT group. For some businesses, VAT grouping will be a useful tool that would simplify accounting for VAT.

Will there be bad debt relief?

VAT registered businesses will be able to reduce their output tax liability by the amount of VAT that relates to bad debt which has been written off by the VAT registered business. The legislation will include the conditions and limitations concerning the use of this relief.

Will there be a margin scheme?

To avoid double taxation where second hand goods are acquired by a registered person from an unregistered person for the purpose of resale, the VAT-registered person will be able to account for VAT on sales of second hand goods with reference to the difference between the purchase price of the goods and the selling price of the goods (that is, the profit margin). The VAT which must be accounted for by the registered person will be included in the profit margin. The legislation will include the details of the conditions to be met in order to apply this mechanism.

How will partial exemption work?

Where a VAT registered person incurs input tax on its business expenses, this input tax can be recovered in full if it relates to a taxable supply made, or intended to be made, by the registered person. In contrast, where the expense relates to a non-taxable supply (e.g. exempt supplies), the registered person may not recover the input tax paid. In certain situations, an expense may relate to both taxable and non-taxable supplies made by the registered person (such as activities of the banking sector). In these circumstances, the registered person would need to apportion input tax between the taxable and non-taxable (exempt) supplies. Businesses will be expected to use input tax (ratio of recoverable to total) as a basis for apportionment in the first instance although there will be the facility to use other methods where they are fair and agreed with the Federal Tax Authority.

What are the cases that would lead to the imposition of penalties?

Penalties will be imposed for non-compliance. Examples of actions and omissions that may give raise to penalties include: A person failing to register when required to do so; A person failing to submit a tax return or make a payment within the required period; A person failing to keep the records required under the issued tax legislation; Tax evasion offences where a person performs a deliberate act or omission with the intention of violating the provisions of the issued tax legislation.

Will there be any special schemes for SMEs?

No special rules are planned for small or medium sized enterprises. However, the FTA will provide materials and resources available for these entities to assist them in their enquiries.

Will there be transitional rules?

Special rules will be provided to deal with various situations that may arise in respect of supplies that span the introduction of VAT. For example: Where a payment is received in respect of a supply of goods before the introduction of VAT but the goods are actually delivered after the introduction of VAT, this means that VAT will have to be charged on such supplies. Likewise, special rules will apply with regards to supplies of services spanning the introduction of VAT. Where a contract is concluded prior to the introduction of VAT in respect of a supply which is wholly or partly made after the introduction of VAT, and the contract does not contain clauses relating to the VAT treatment of the supply, then consideration for the supply will be treated as inclusive of VAT. There will, however, be special provisions to allow suppliers to charge VAT in situations where their recipient is able to recover their VAT but where there is no VAT clause.

How will insurance be treated?

Generally, insurance (vehicle, medical, etc) will be taxable. Life insurance, however, will be treated as an exempt financial service.

How will financial services be treated?

It is expected that fee based financial services will be taxed but margin based products are likely to be exempt.

How will Islamic finance be treated?

Islamic finance products are consistent with the principles of sharia and therefore often operate differently from financial products that are common internationally. To ensure that there are no inconsistencies between the VAT treatment of standard financial services and Islamic finance products, the treatment of Islamic finance products will be aligned with the treatment of similar standard financial services.

How can one object to the decisions of the Authority?

Any person will be able to object a decision of the Federal Tax Authority. As a first step, the person shall request the FTA to reconsider its decision. Such request of re-consideration has to be made within 20 business days from the date the person was notified of the original decision of the FTA, and the FTA will have 20 business days from receipt of such application to provide its revised decision. If the person is not satisfied with the revised decision of the FTA, it will be able to object to the Tax Disputes Resolution Committee which will be set up for these purposes. Objections to the Committee will need to be submitted within 20 business days from the date the person was notified of the FTA’s revised decision, and the person must pay all taxes and penalties subject of objection before objecting to the Committee. The Committee will typically be required to give its decision regarding the objection within 20 business days from its receipt. As a final step, if the person is not satisfied with the decision of the Committee, the person may challenge its decision before the competent court. The appeal must be made within 20 business days from the date of the appellant being notified of the Committee’s decision.

Changing my business systems for VAT reporting will cost money. Can the government help?

When VAT is introduced, the government will provide information and education to businesses to help them make the transition. The government will not pay for businesses to buy new technologies or hire tax specialists and accountants. That is the responsibility of each business. We will, however, provide guidance and information to assist you and we are giving businesses time to prepare.

What are the penalties for not complying with a business’s VAT responsibilities?

Everyone is urged to fully comply with their VAT responsibilities. The government is currently in the process of defining the exact fees and penalties for non-compliance. Administrative penalties for violations will be decided by Cabinet and announced after issuance. There will be further penalties decided by Courts in the case of tax evasion.

Will FTA issue rulings or provide tax advice?

In the course of its interaction with taxpayers, the FTA may provide its views on various matters in the law. Taxpayers may choose to challenge these views. It should be noted that penalties may be imposed on taxpayers who are found to violate any tax laws and regulations.

Will it be possible to issue cash receipts instead of VAT invoices?

A supplier registered or required to be registered for VAT must issue a valid VAT invoice for the supply. To be considered as a valid VAT invoice, the document must follow a specific format as mentioned in the legislation. In certain situations the supplier may be able to issue a simplified VAT invoice. The conditions for the VAT invoice and the simplified VAT invoice are mentioned legislation.

Will there be any VAT that businesses are not allowed to claim?

VAT will not be deductible in respect of expenses incurred for making non-taxable supplies. Furthermore, input tax cannot be deducted if it is incurred in respect of specific expenses such as entertainment expenses e.g. employee entertainment.

Under which conditions will businesses be allowed to claim VAT incurred on expenses?

VAT on expenses that were incurred by a business can be deducted in the following circumstances: The business must be a taxable person (the end consumer cannot claim any input tax refund). VAT should have been charged correctly (i.e. unduly charged VAT is not recoverable). The business must hold documentation showing the VAT paid (e.g. valid tax invoice). The goods or services acquired are used or intended to be used for making taxable supplies. VAT input tax refund can be claimed only on the amount paid or intended to be paid before the expiration of 6 months after the agreed date for the payment of the supply.

Tell me more about supply of goods.

A supply of goods includes the transfer of ownership of the goods or the right to use them as an owner from one person to another and an entry into a contract between two parties triggering the transfer of goods at a later time

Those who supply service will be taxed. What is it exactly?

A supply of service is any supply that is not considered a supply of goods

Which supplies of service are VAT-exempt?

The issuance or sale of any voucher unless the received consideration exceeds its declared monetary value; and the transfer of whole or an independent part of a business from a person to a taxable person for the purposes of continuing such business that was transferred.

Will VAT also apply to government entities?

It depends on the kind of supply of service that the government entity is doing. A government entity is regarded as making a supply if said entity was not performing activities in sovereign capacity or if its activities are in competition with the private sector.

Who decides which government activities are sovereign or not?

The Cabinet issues a decision determining specific Government entities whose activities are considered as “activities in sovereign capacity” and instances where these activities are considered not in competition with the private sector.

Tell me more about deemed supply

A supply is considered “Deemed” if the supply of goods or services was all or part of a taxable person’s assets, but no longer considered to be as such (provided the supply was made without consideration). Similarly, the supply is Deemed if implemented through a transfer by a Taxable Person of Goods forming part of his business assets from the UAE to another VAT-implementing GCC state, or from the Taxable Person’s business in a VAT implementing GCC state to his business in the implementing state, unless, in either case, that transfer: is treated as temporary under the Customs Legislation; or is made as partof another Taxable Supply of these Goods. The same applies to the supply of goods or services for which Input Tax may be recovered but was used, in part or whole, for purposes other than Business, but only to the extent of non-Business use, as well as for Goods in the ownership of the Taxable Person as at the date of Tax Deregistration.

Can the tax authority make changes to tax registration?

The Authority has the right to make changes to the persons registered as a Tax Group by removing or adding persons based on the instances mentioned in the Executive Regulation or as requested by the Taxable Person.

Can anyone not obliged to apply for tax registration still register?

Any person who is not obligated to apply for Tax Registration may apply if, at the end of any given month, the total value of taxable supplies or expenses that were subject to Tax incurred during the previous 12-month period exceeded the Voluntary Registration Threshold. The same applies in the event where it is anticipated that the total value of taxable supplies to be made or expenses, which were subject to Tax to be incurred will exceed the Voluntary Registration Threshold during the coming 30-day period.

Can a non-UAE resident use import value to apply for tax?

A non-resident person may not take the value of goods and services imported into the UAE for the purpose of calculating whether they are entitled to apply for tax registration if the charging of tax for such goods or services is the duty of the importer, as defined in the Decree-Law.

How do you know if a person has exceeded the registration threshhold?

To determine whether a person has exceeded the mandatory registration threshold and the voluntary registration threshold, the total sum of the following is calculated: The value of Taxable Supplies made by the person; the value of concerned goods and concerned services received by the Person; the value of the taxable supplies made by the acquired whole or part of the business, if a person acquires a whole or part of another business; and the value of taxable supplies made by related parties.

When do you apply for tax deregistration?

A registrant must apply to the Authority for tax deregistration if he no longer makes taxable supplies; or if the value of the taxable supplies made over a period of 12 consecutive months is less than the voluntary registration threshold. They may also apply for tax deregistration if the value of taxable supplies during the past 12 months was less than the mandatory registration threshold.

How is payable tax calculated?

Payable Tax for any tax period is calculated as the total Output Tax (i.e. the tax that the taxable person has charged on his supplies) during the said period less the total Input Tax recoverable by that Taxable Person over the same Tax Period (i.e. the tax that he has paid on supplies to him or imports by him).

What do we do about tax returns?

Businesses in the UAE must submit a Tax Return to the Authority at the end of each Tax Period in accordance with the timeframes and procedures specified by law. Businesses must declare all supplies made and received during that Tax Period. If a Taxable Person acquires or imports a Capital Asset, the Taxable Person must assess the period of use of that asset and make the necessary adjustments to the Input Tax paid pursuant to the Capital Assets Scheme.

Tell me more about tax-keeping records

Businesses are required to retain records of their Capital Assets for at least ten years. A registrant making a taxable or deemed supply shall issue an original tax invoice and deliver it to a recipient of goods or services or keep it in his records in the event of a lack of recipient. Any person who receives an amount as Tax pursuant to any document issued by the person must pay this amount to the Authority. A registrant shall issue a tax invoice within 14 days of the date of supply. The Decree-Law specifies that the Executive Regulation shall include the information to be included in the Tax Invoice; conditions and procedures required to issue an electronic Tax Invoice; instances where the Registrant is not required to issue a Tax Invoice to the Recipient of Goods or Services; instances where other documents may be issued in place of the Tax Invoice, as well as their specifications and the information to be included therein; and instances where another Person may issue a Tax Invoice on behalf of the Registrant supplier. The Federal Decree-Law on VAT is available in full on: www.mof.gov.ae and www.tax.gov.ae.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