Cabinet Decision No. 100 of 2024 · UAE Federal
The 2024 overhaul of the VAT Executive Regulation, effective 15 November 2024, adding Articles 3 bis and 14 bis and amending Articles 1, 2, 4, 7, 8, 14 and many others on supplies, deemed supplies, registration, deregistration, tax invoices, input tax and exempt financial services; the FTA publishes it as the consolidated regulation showing each change by footnote.
Cabinet Decision No. 100 of 2024 is the 2024 overhaul of the VAT Executive Regulation, Cabinet Decision No. 52 of 2017. It was issued on 6 September 2024 and its amendments took effect on 15 November 2024; the Federal Tax Authority publishes it only as part of the consolidated Executive Regulation, whose header records the decision and its effective date and whose footnotes mark each article amended or added by it. It is in force.
The footnotes show amendments across the regulation: Articles 1, 2, 4, 5, 7, 8, 14, 15, 16, 23, 29, 30, 31, 33, 34, 35, 37, 38, 41, 42, 46, 50, 52, 53, 55, 58, 59, 60 and 64, covering definitions, supplies, deemed supplies, registration and deregistration, tax groups, zero-rating of exports and transport, residential and charity buildings, healthcare, financial services, imports, input tax recovery and apportionment, capital assets, invoices, credit notes and returns, together with two new provisions, Article 3 bis on transfers of government real estate between government entities and Article 14 bis on deregistration to protect the integrity of the tax system.
The provisions clients meet most, in their amended form, are these. Article 1 now defines Virtual Assets as a digital representation of value that can be traded or converted and used for investment, excluding digital fiat currency and securities, and defines a Business Day. Article 42 exempts the transfer of ownership and conversion of Virtual Assets, with effect for supplies made on or after 1 January 2018, and exempts fund management services supplied independently for a consideration to funds licensed by a UAE authority. Article 14 requires a deregistration application within 20 business days of the triggering event and Article 14 bis lets the FTA deregister on its own initiative a person who no longer meets the requirements or has not completed deregistration. Article 30 keeps the 90-day export window for zero-rating goods and spells out the evidence required; Article 31 zero-rates services to recipients outside the Implementing States who are outside the UAE when the service is performed, treating a presence of under 30 days not connected with the supply as being outside the State, and withholds zero-rating where another person in the UAE receives the service with non-recoverable input tax. Article 53 blocks input tax on non-employee entertainment, personal-use vehicles and free employee benefits, save for benefits required by labour law or documented policy and health insurance for the employee, one spouse and up to three children under 18. Article 59 requires a tax invoice within 14 days of supply, allows simplified invoices up to AED 10,000 and summary invoices within 14 days of month-end, and Article 55 requires an annual apportionment adjustment where the difference exceeds AED 250,000.
Every VAT registrant and every person required to register in the UAE, together with businesses relying on the registration exceptions, exporters of goods and services, financial and virtual asset service providers, fund managers, employers recovering input tax on staff benefits and anyone issuing tax invoices or credit notes, because the amended Executive Regulation sets the detailed rules for applying Federal Decree-Law No. 8 of 2017.
English official text in 67 articles. Open the full text or jump to a provision:
| Article 1 | Amended definitions, including Virtual Assets as a digital representation of value that can be traded or converted digitally and used for investment, excluding digital fiat currencies and financial securities, and Business Day as a working day other than weekends and federal holidays. |
| Article 3 bis | A new article treating transfers of government buildings and real estate between government entities as outside the scope of supply. |
| Article 8 | Voluntary registration at AED 187,500 requires an applicant relying on expected supplies to evidence an intention to make taxable supplies or incur taxable expenses above the threshold within 30 days, and to prove it carries on business in the State. |
| Article 14 | A registrant must apply for deregistration within 20 business days of the triggering event; the FTA confirms the effective date within 10 business days, may deregister on its own initiative once satisfied, and the registrant must settle all tax and penalties and file a final return, with assets deemed supplied immediately before deregistration. |
| Article 14 bis | A new power for the FTA to deregister a person where continued registration could harm the integrity of the tax system, in particular where the person no longer meets the registration requirements or has not applied for or completed deregistration. |
| Article 15 | The FTA must deregister a tax group whose members no longer qualify, whose association has ended or whose continuation would enable tax evasion or significantly reduce revenue, and the representative member must notify ineligibility of a member within 20 business days. |
| Article 30 | Exports of goods are zero-rated where the goods leave the Implementing States or enter customs suspension within 90 days of supply and the exporter holds a customs declaration with commercial evidence, a shipping certificate with official evidence or proof of suspension; the FTA may extend the period on written application. |
| Article 31 | Services are zero-rated where the recipient has no residence in an Implementing State and is outside the UAE when the service is performed and the service is not connected with UAE real estate or performed in the UAE; a presence under 30 days not connected with the supply counts as being outside the State, and zero-rating is denied where another UAE person receives the service with non-recoverable input tax. |
| Article 42 | Financial services exemptions now cover fund management services supplied independently for a consideration to funds licensed by a UAE authority, and the transfer of ownership and conversion of Virtual Assets, applying to supplies made on or after 1 January 2018. |
| Article 53 | Input tax is not recoverable on entertainment for non-employees, motor vehicles available for personal use or free employee benefits, except benefits required by labour law or a documented policy normal for the role, deemed supplies and health insurance for the employee, one spouse and up to three children under 18. |
| Article 55 | Mixed input tax is apportioned by the taxable-supply percentage each period and recalculated for the tax year, with an adjustment where the annual difference from actual use exceeds AED 250,000; alternative methods may be requested and kept for at least two tax years. |
| Articles 59–60 | A tax invoice must be issued within 14 days of the date of supply; simplified invoices are allowed to non-registrants and where consideration does not exceed AED 10,000; summary invoices covering a month are delivered within 14 days of month-end; invoices and credit notes may be electronic where securely stored with guaranteed authenticity and integrity. |
The Executive Regulation sets no fines of its own; failures to register, deregister, issue invoices or file returns under its rules are penalised under Cabinet Decision No. 40 of 2017 as amended, including by Cabinet Decision No. 129 of 2025, and under the Tax Procedures Law. Late export evidence results in tax at the domestic rate under Article 30(9).
Most of the VAT advice we give today traces back to this amendment. For free zone and mainland clients exporting services we apply the amended Article 31 test, checking where the customer is when the service is performed and whether anyone in the UAE benefits, because the 2024 wording closed the gap that used to let a short UAE visit pass. For trading clients we build the Article 30 export file of customs declarations and waybills into their invoicing workflow so the 90-day window is met. Crypto and fund clients rely on Article 42, where the exemption for virtual asset transfers and conversions reaches back to 2018 and the fund management exemption applies only to funds licensed in the UAE, which changes their input tax recovery. On the compliance side we diarise the 14-day invoice rule in Article 59 and the 20-business-day deregistration rule in Article 14, and we warn dormant registrants that Article 14 bis now lets the FTA remove them and treat their assets as supplied.
| Amends | Cabinet Decision No. 52 of 2017 |
| Cites | VAT Executive Regulation · VAT Law |
| Cited by | VAT Executive Regulation |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
VAT Executive Regulation
The detailed VAT rules: the AED 375,000 mandatory and AED 187,500 voluntary registration thresholds, tax groups, place and date of supply, zero-rating and exemption condi…
VAT Law
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VAT Law Amendment (2022)
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VAT Designated Zones Decision
Lists the VAT designated zones (fenced free zones treated as outside the UAE for certain supplies) as amended by five later decisions; RAK Airport Free Zone was removed f…
Tax Procedures Law
The common procedural code for all federal taxes: registration, record keeping, returns, voluntary disclosures, FTA audits and assessments, tax agents, administrative pen…
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