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UAE VAT 2025: Key Clarifications on Exports, Designated Zones & Compliance

he Federal Tax Authority (FTA) and UAE authorities have introduced important clarifications affecting VAT treatment in 2025. While the standard VAT rate remains 5%, the FTA’s updated guidance refines when exports can be zero-rated and clarifies VAT treatment inside Designated (free) Zones. This article breaks down the practical points every business owner, finance manager, and tax advisor should know — and the compliance steps you must take to avoid surprises during audits.


1. VAT rate remains 5% — but zero-rating rules tightened

The headline: VAT is still 5%, but the rules for applying the 0% (zero-rating) for exports have been tightened. The FTA’s 2024–2025 amendments and the subsequent Public Clarification make clear that zero-rating for exports (goods and services) is only available when the documentary and substantive conditions are fully met. If required export evidence is missing or incomplete, the FTA can disallow zero-rating and assess VAT and penalties.

What to do:

  • Keep a complete export file for each shipment or service (contracts, commercial invoices, shipping docs, customs declarations, proof of recipient outside the UAE, etc.).

  • Review existing export transactions and ensure supporting evidence meets the updated list of acceptable documents introduced from the effective date.


2. Export documentation — what the FTA is asking for now

The FTA’s clarifications list specific document combinations that will substantiate zero-rating of exported goods (for example, customs declarations paired with commercial evidence or shipping certificates with official export evidence). These clarifications became effective after the Executive Regulation amendments and are part of Public Clarification VATP040. Failure to maintain acceptable combinations can result in reclassification of supplies.

Practical checklist for goods exports:

  • Valid commercial invoice showing export value and recipient outside the UAE.

  • Shipping documents (bill of lading, airway bill) and/or customs export declaration.

  • For customs-suspension movements, evidence that goods were placed under the applicable suspension regime.

3. Zero-rating of export of services — more clarity and stricter tests

The amendments also refine when export of services can be zero-rated. The FTA clarified that services exported to a non-UAE recipient must not be received in the UAE and must meet the revised conditions in the Executive Regulation (Article 31 and related clarifications). Certain services directly connected to UAE-based assets or real estate will not qualify. Read the tests carefully before applying zero-rating to services.

Example implications:

  • A consultancy performed partly inside the UAE or provided in connection with UAE real estate is unlikely to qualify for 0% treatment.

  • Where services are performed entirely outside the UAE and received by a non-UAE resident, 0% may apply provided evidence supports the position.


4. Designated (Free) Zones — goods vs services treatment

Designated Zones (sometimes called designated free zones) retain special VAT treatment for goods under certain conditions — but services supplied in these zones are generally taxable at 5% under UAE VAT law. Not all free zones are “Designated Zones”; only those meeting strict FTA customs-control criteria qualify for the special goods treatment. Ensure you know whether your zone is a “Designated Zone” and whether the activity is goods or services.

Action points for free-zone businesses:

  • Confirm whether your free zone is officially listed as a Designated Zone by the FTA.

  • Treat goods transfers between designated zones and exports carefully — keep customs and shipping evidence.

  • Assume services supplied in the zone are taxable unless a specific exemption applies.


5. Input VAT recovery — follow the updated guidance

The FTA’s clarifications and guidance also affect input VAT recovery, especially for businesses operating across mainland and free-zone jurisdictions. Input claims must be supported by appropriate invoices and used in accordance with the new rules and apportionment guidance where supplies are mixed (taxable vs exempt). Taxpayers should align their VAT recovery processes with the FTA’s updated framework to avoid future disallowances.

6. Compliance & record-keeping — the single most important defense

Given the stricter documentary tests, strong record-keeping is now essential. The FTA will expect files that make the zero-rating position clear and verifiable. This includes retained digital copies of invoices, transport docs, customs paperwork, contracts, and any correspondence proving that the recipient and consumption are outside the UAE.

Recommended internal controls:

  • Standard export file template for each transaction.

  • Regular internal VAT file audits (sample-check shipments and services).

  • Cross-team coordination between sales, logistics, customs clearance, and finance to ensure documents are issued and stored correctly.


7. Short checklist before you publish a VAT zero-rating claim

  1. Confirm the nature of the supply (goods vs services).

  2. Verify recipient is outside the UAE and the place of supply under VAT rules.

  3. Collect the required documentary evidence combination specified by the FTA.

  4. Ensure VAT invoices, customs declarations, and transport documents are consistent.

  5. Review whether the supply involves a Designated Zone and apply the correct treatment.


Conclusion — act now, document consistently

The FTA’s 2024–2025 clarifications tighten the conditions for zero-rating exports and confirm that services in Designated Zones remain taxable in most cases. Businesses that export goods or provide cross-border services must review their processes and documentation now to ensure zero-rating positions are fully supported.

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