How to update VAT registration information that has expired?

VAT has now been in place for almost a year and therefore most registered companies will have renewed their trade license since they first registered for VAT. The FTA requires information uploaded at the time of registration to be updated each year as it expires. This includes the trade licence and the passports and Emirates IDs of the company owners.

To start the amendment, click on the link on your FTA dashboard. Once you start an amendment you are prompted to re-enter your Emirates ID and passport even if the documents uploaded at registration are still valid. Then work your way through the amendment pages which follow the format of the initial VAT registration.

While the portal does not force you to update the annual turnover or upload your most recent year-to-date financial statements, several VAT experts suggest doing this as you need to certify on the last page that the information you are submitting is correct. Note the FTA request that the amendment is filed within five working days to avoid difficulties.

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Can I take on new orders without a TRN Number?

Once you have submitted your voluntary tax application on the FTA’s online portal you have to wait until they have reviewed the uploaded information and the registration is accepted before you can submit invoices with VAT included. Until that point, raise invoices that do not mention the words VAT or TAX and do not add VAT to the amount invoiced. Including VAT in the invoice is against the Decree Law and would result in fines and penalties if later identified during an FTA audit.

Between applying for your VAT registration and receiving your TRN, you should not lose customers, you just have to invoice them without VAT. However, as you don’t yet know the date you will received your TRN and the effective date of registration the FTA will give you, I suggest advising customers in advance that your invoice may or may not include VAT. If your customers are VAT registered, they should be indifferent to this as they can reclaim any VAT charged. Non-VAT registered customers will be most affected as they may get an invoice without VAT or pay 5 per cent more if you need to invoice them with the tax applied. What you want to avoid is raising invoices without VAT and the FTA backdating your registration to the start of the month. If that happens, you would have to account for the tax on the revenues already invoiced even though you have not charged it to your customers.

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What is GIBAN shown on my FTA tax page?

The GIBAN is a special bank account number created for every taxpayer by FTA to facilitate the payment of VAT via any UAE bank. You can add FTA as a beneficiary and use the GIBAN assigned to you as their IBAN (Account number). Now when you make a payment using this GIBAN to FTA, it will be credited to your account.

It is advisable that you check on the FTA site after 24 hours to ensure that the payment is reflected against your account. This can be viewed under Transaction History tab.


Who are the registered tax agents for UAE?

As of March 18, 2018, the FTA website lists the following tax agents.  This list is subject to revision hence please visit the link below to view the updated list: https://www.tax.gov.ae/registered-tax-agents.aspx

Registered Tax Agents

Tax Agent Name Registered Date Tax Agency TAAN TAN
Asad Zuhair Sado Abbas 13-02-2018 Asad Abbas & Co. (Chartered Accountants) 20029690 30003776
Yaser Yasin Darwish 15-02-2018 Da Gate Hub Management Consultancies 20010898 30002554
Younis Ali Almulla 15-02-2018 Almulla For Accounting & Tax Services 20019121 30001572
Jadd Shalak 15-02-2018 Averyx Management Consultancies 20038519 30004899
Majid Abdulrahman Alshaikh 15-02-2018 Majid Alshaikh Consultancy 20040937 30000970
Hamdan Zakaria Awda 20/02/2018 Hamdan Awda Chartered Accountants 20024600 30001481
Yasser Atiyyeh 22/02/2018 XB4 Solutions(Dubai Branch) 20013751 30000657
Hamad Abdulla Alshamsi 22/02/2018 Prestige Auditing L.L.C 20013249 30003271
Mohamed Mostafa Kamel Yousef El Agha 26/02/2018 Osol Al Khebra Accounting & Bookkeeping LLC 20044764 30001200
Anssar Mohammed Ahmed Siddiq 26/02/2018 Verify Accounting & Consulting 20031027 30003537
Muhanned Anbari 27/02/2018 Becker for Financial Solutions LLC 20038642 30004279
Fuad Ibrahim Muflih Alomari 27/02/2018 Al Khaleej Tax Consultancy L.L.C 20009221 30004766
Ahmed Maher Mohamed Hassanien 28/02/2018 Ahmed Hassanien and Co Auditing of Accounts 20013090 30003727
Ratheesh Mekkat 28/02/2018 Al Mithaq Tax Consultancy 20008090 30001259
Abdel Hameed Zaitoun 8/3/2018 Genome Consulting 20032520 30000640
Ahmad Wafi Kanafani 8/3/2018 Kanafani Tax Services 20001749 30000863
Ghassan S. M. Jamoos 11/3/2018 Al Zarooni Tureva Auditing 20036596 30000343

Do business selling across the GCC register in each country?

A business selling across the GCC will only be required/entitled to register for VAT in another member state if the nature of its supplies of goods and services requires it to be (e.g. the place of supply is in another GCC member state and the reverse charge mechanism cannot be used).

Source: Deloitte

Will there be group registration for companies in the GCC?

Based on the GCC Agreement, member states do have the discretion to implement VAT groups. The UAE and KSA laws indicate that grouping will be available for groups of legal persons established in these respective countries, depending on control requirements being met.

Source: Deloitte

If only residents can be VAT registered, does this mean that offshore companies cannot be VAT registered?

There is a requirement for non-residents to register for VAT in the GCC, in the event that they need to pay VAT on supplies made by them in a GCC member state (e.g. the place of supply is in the GCC and the customer is not able to self-account for the VAT due under the reverse charge mechanism).

Source: Deloitte

What do we know about the establishment VAT registration requirement?

If an entity has a Permanent Establishment (PE) for corporate tax purposes in a member state, then it is very likely to also have an establishment for VAT purposes in that country. The bar for a PE is arguably higher than that for having an establishment for VAT purposes. Where it is unclear which establishment of a legal entity (i.e. the head office or the PE) has made the supply then an analysis would be required as to the establishment most closely connected with the supply. Where such a PE is considered to be making taxable supplies, a VAT registration would be required.

Source: Deloitte

What is the method of registration for VAT?

VAT registration is expected to be largely online. Additional documentation may be requested offline (likely to vary by GCC member state).

Source: Deloitte

When to use your VAT number?

A customer VAT number will be needed to enable a supplier of goods and services to a recipient in another GCC country to invoice without VAT. In the long run, a portal to enable the checking of VAT numbers is expected to be made available.

Source: Deloitte