[Global IDT Insights] UAE Issues VAT Guide on Administrative Exceptions

UAE VAT Administrative Exceptions Guide

Editorial Team – [2026] 182 taxmann.com 46 (Article)

Global IDT Insights provides a weekly snippet of tax news specifically related to Indirect Taxes from around the globe.

1. UAE has issued a VAT guide on administrative exceptions

UAE has issued a VAT guide on administrative exceptions outlining the circumstances in which VAT registrants may apply for concessions permitted under the VAT Law and the Executive Regulation. The guide explains the eligibility criteria, procedural requirements, and decision-making process applicable to VAT administrative exception requests.

The guide is limited to specific administrative exceptions expressly provided under the Executive Regulation and clarifies the scope, legal framework, and status of such exceptions. It also sets out the documentation, timelines, and conditions applicable to applications submitted through EmaraTax.

Key aspects of this guide include:

(a) Limited scope of VAT administrative exceptions – VAT administrative exceptions are available only for cases explicitly provided under the Executive Regulation. These include exceptions relating to Tax Invoices, Tax Credit Notes, alternative evidence to prove export of goods, and extensions of the time period to export goods. The guide clarifies that administrative exceptions do not extend to VAT refunds, VAT registration matters, waiver of administrative penalties, or other VAT technical issues.

(b) Eligibility restricted to VAT registrants and authorised applicants – Only VAT registrants are eligible to apply for a VAT administrative exception. Applications must be submitted by an authorised signatory, an appointed Tax Agent eligible for indirect taxes, or a court-appointed legal representative. In the case of a tax group, applications must be submitted by the representative member or its appointed Tax Agent.

(c) Defined eligible cases and statutory conditions – The guide specifies eligible cases for each category of administrative exception, along with the statutory references and conditions that must be satisfied. These include demonstrating impracticality in issuing or detailing Tax Invoices or Tax Credit Notes, justifying the need for alternative export evidence, or establishing circumstances beyond the supplier’s and recipient’s control for extending export timelines. Applications falling outside these defined cases will be rejected.

(d) Clarification on documentary evidence for export of goods – The guide reflects amendments to the documentary evidence required to prove export of goods with effect from 15-11-2024. It specifies acceptable combinations of customs declarations, commercial evidence, shipping certificates, and official evidence. Where a registrant is unable to obtain the prescribed combinations, an administrative exception may be requested through EmaraTax.

(e) Administrative exception application process via EmaraTax – The guide details the end-to-end process for submitting administrative exception requests through EmaraTax, including application steps, supporting documentation, and file requirements. It also sets out timelines for submission, consequences of incomplete applications, and automated closure of requests not finalised within prescribed business days.

(f) FTA review, decision timelines, and validity period – The Federal Tax Authority may accept, request further information, or reject applications based on completeness and eligibility. The guide specifies response timelines of 25 or 45 business days, depending on the category of exception. Approved administrative exceptions are generally valid for three years, subject to earlier expiry if relevant legislative provisions are amended or repealed.

Source – Official Guidance

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