TAX

Tax Alert - E-Invoicing in the UAE: Release of public consultation paper

insight featured image
The Ministry of Finance (MoF) has issued a public consultation paper on e-invoicing, marking a major milestone in the UAE's digital transformation. Stakeholders are encouraged to provide their feedback by February 27, 2025.

Tax authorities across the GCC are driving a major digital transformation in tax administration, with e-invoicing systems at the forefront of this change. Similarly, the e-invoicing initiative in the United Arab Emirates (UAE) represents a significant advancement in the nation's digital infrastructure, aiming to enhance compliance, streamline audit processes, and provide policymakers with near real-time data for more informed decision-making. 

Over the last year, the UAE Ministry of Finance (MoF) has released incremental updates to the centralised model of e-invoicing. However, yesterday marked a significant milestone as the MoF released a public consultation paper on e-invoicing. 

The consultation paper was issued to allow businesses to comment on the proposed elements of the UAE e-invoicing framework. 

It details the key data elements, fields, and attributes for 16 commonly used invoice types in the UAE, including standard tax invoices, reverse charge mechanism supplies, and zero-rated supplies. 

Each data field adheres to both global specifications and UAE-specific standards. For example, a standard tax invoice comprises 50 mandatory fields, with 15 fields currently not covered under the UAE VAT Law.

Impact on businesses 

E-invoicing requirements extend to all businesses operating in the UAE, irrespective of their VAT registration status. The seller and buyer will be identified through their Tax Identification Number (TIN), which is the first 10 digits of their Tax Registration Number (TRN), if they are registered for VAT or Corporate Tax in the UAE. Businesses not registered with the FTA (i.e., they don’t have a TRN) will be required to register to obtain a TIN. 

The implementation of e-invoicing will be phased, potentially based on industry or turnover. Consequently, both taxable and non-taxable entities must comply with e-invoicing regulations. 

Key takeaways

The consultation paper highlights several key areas for consideration, including the need to capture all mandatory data fields for each use case scenario. One significant challenge is managing HSN/Service codes, which will transition from optional to mandatory. It is important to note that most businesses in the UAE currently do not maintain internationally accepted HSN codes for goods or service codes. 

Additionally, e-invoices will be required for all invoicing scenarios in the UAE, including commercial invoices, out-of-scope invoices, and invoices for exempt supplies. Therefore, businesses will have to assess these scenarios and consider how the respective data fields will be captured. 

Key dates

27 February 2025: Deadline to provide feedback on the consultation paper, to ensure that all required fields for your business transactions are included in the underlying ‘data dictionary’ and whether any clarification is needed on the data element definitions.

End of February: MoF is expected to release accreditation procedures for Accredited Service Providers (ASPs). 

July 2026: Go-live date for e-invoicing in the UAE.

Next steps 

  • Conduct a gap analysis: Assess your current invoicing processes, including any manual processes, and identify gaps between your practices and the UAE e-invoicing framework. 
  • Develop a project plan: Outline the timeline, milestones, and responsibilities for e-invoicing implementation, including key dates like the pilot phase and go-live dates. 
  • Engage with consultants and ASPs: Early engagement is crucial for a seamless transition. 

How we can help

We can assist your business in navigating the complexities of e-invoicing implementation in the UAE. Our team of e-invoicing and VAT experts offer comprehensive support, ensuring your ERP system is fully equipped to handle all e-invoicing requirements. We also partner with ASPs to ensure a seamless transition. 

For more information on how GT can support your e-invoicing needs, please reach out to our experts.