Implements the Excise Tax Law: registration and deregistration, tax liability and the person responsible, designated zones and warehouse keepers, exemptions, calculation of the excise price, tax returns, payment and refunds; consolidated text as amended by Cabinet Decisions No. 108 of 2023 and No. 198 of 2025.
Cabinet Decision No. 37 of 2017 is the Executive Regulation of the Excise Tax Law. It has applied since 1 October 2017 and remains in force as amended by Cabinet Decision No. 108 of 2023 (effective 1 December 2023) and Cabinet Decision No. 198 of 2025 (effective 1 January 2026). It supplies the operating detail the Decree-Law leaves open: who else pays when the primary taxpayer defaults, how registration and deregistration work, what a designated zone and a warehouse keeper must do, when goods are released for consumption, how exports are exempted and deductions and refunds are claimed, and the monthly return cycle.
Article 2 widens liability: if the producer, importer or releasing party does not pay, anyone in the supply chain, any investor with a financial interest in it and the owner of the goods become liable, and a warehouse keeper pays when goods leave a designated zone untaxed if it kept no records, breached FTA conditions or benefited from the default. Article 3 requires a registration application with a financial security, obliges the FTA to respond within 20 business days and backdates registration to the first day of the month in which the activity began; the FTA may register a person itself. Article 4 lets the FTA except importers who import or release goods no more than once in six months, although four occasions in 24 months counts as regular. Article 6 requires deregistration within 30 days of ceasing to be liable.
Article 9 sets out warehouse keeper registration and the conditions the FTA may attach, including quantity limits, a financial security per zone and physical security. Article 11 defines the stockpiler: a person holding excess untaxed goods above its average monthly stock over the previous 12 months, or above two months of average sales; without audited stock records the whole stock can be treated as excess and taxed in full. Article 12 fixes when goods are released for consumption, including shortages in a designated zone unless reported within 30 days with a justified cause. Article 14 exempts direct and indirect exports where goods move in customs suspension and the exporter holds a customs declaration with commercial evidence or a shipping certificate with official evidence. Article 15 defines designated zones, requires registration by the warehouse keeper, allows a financial guarantee, and sets the records and transfer document for zone-to-zone movements.
Articles 17 to 19 make the tax period a calendar month with the return and payment both due by the 15th day of the following month. Article 21 requires excess tax refunds to be paid within two months of the claim or 21 days after an audit, and lets the FTA withhold refunds while returns are outstanding. Article 22 covers refunds to diplomatic bodies, GCC-registered exporters and, since 1 June 2024 and as revised from 1 January 2026, non-registered businesses that export previously taxed goods.
Excise taxable persons (producers, importers, stockpilers and persons releasing goods from designated zones), warehouse keepers and operators of designated zones, persons in an excise supply chain who may become secondarily liable, non-registered exporters claiming refunds, and the customs departments that reconcile excise goods on import and export.
| Article 2 | If the primary taxpayer fails to pay, anyone in the supply chain, any investor with a financial interest in it and the owner of the goods are liable; a warehouse keeper is liable for goods released untaxed where it kept no records, breached FTA conditions or benefited from the default; a stockpiler is not liable if its goods are not excess goods. |
| Article 3 | Registration requires an application, a financial security and any extra record-keeping the FTA sets; the FTA responds within 20 business days; registration takes effect from the first day of the month the activity began and the FTA may register a person of its own motion. |
| Article 4 | The FTA may except a person who does not regularly import or release excise goods, meaning no more than once in six months, but four occasions in 24 months counts as regular; an excepted person pays the tax on or before import and must notify changes within 20 business days. |
| Article 6 | A registrant must apply to deregister within 30 days of ceasing to be liable, is deemed no longer liable six months after ceasing the activities, and must first settle all tax, penalties and returns; the FTA may deregister a person itself. |
| Article 9 | Anyone operating a designated zone must register as a warehouse keeper; the FTA may cap the quantity and type of goods held, require a financial security per zone, impose reporting, physical security, stock checks and entry and exit controls. |
| Article 11 | A stockpiler holds excess excise goods in free circulation on which tax was not paid, meaning stock above its 12-month average monthly level or above two months of average sales; without audited stock records the FTA may treat the whole stock as excess and tax it in full. |
| Article 12 | Goods are released for consumption on production in the UAE or on leaving a designated zone into free circulation, including consumption inside the zone, transfer irregularities and shortages, unless a shortage is reported within 30 days with a justified cause or results from natural characteristics. |
| Article 14 | Exported goods are exempt if not released for consumption and moved in customs suspension; direct and indirect exports require a customs declaration with commercial evidence or a shipping certificate with official evidence, and the goods must not be used or altered before export. |
| Article 15 | A designated zone is a fenced free zone with security, customs supervision and a warehouse keeper, or an FTA-specified area meeting similar conditions; it is registered by the warehouse keeper, may require a guarantee, and zone-to-zone transfers need a transfer document and receipt confirmation. |
| Articles 17–19 | The tax period is the Gregorian month; the return and the payment are each due no later than the 15th day of the following month; customs departments reconcile excise goods against import and export declarations using a tax risk matrix. |
| Article 21 | Excess tax refunds are paid within two months of the claim or 21 days after an audit; the FTA need not refund until two tax periods have passed and may withhold a refund while any return is outstanding. |
| Article 22 | Refunds are available to foreign governments and diplomatic bodies, to GCC-registered persons who re-export to another implementing state, and to non-registered businesses that directly or indirectly export goods on which tax was paid (clauses in effect from 1 June 2024, revised from 1 January 2026), with a minimum one-month claim period and decision within 20 business days. |
The regulation sets no fine amounts; those are in Cabinet Decision No. 40 of 2017 as amended. Its practical sanctions are structural: the FTA may register a person compulsorily with effect from the month liability arose (Article 3(5)), tax an entire stock as excess where audited records are missing (Article 11(5)), treat a non-compliant designated zone as inside the UAE (Article 15(5)), hold warehouse keepers and supply chain participants liable for unpaid tax (Article 2), and withhold refunds while returns are outstanding (Article 21(6)).
This is the regulation our excise clients live by month to month. The 15th-of-the-month deadline for both the return and the payment is a hard date we diarise for every registrant, and because Article 3 backdates registration to the first day of the month in which trading began, we register importers before their first shipment rather than after. For clients who want a bonded facility we prepare the warehouse keeper and designated zone applications together, including the financial security and the stock record system Article 15(9) demands, since a zone that breaches its conditions is treated as onshore and the keeper becomes liable for the tax. We also warn distributors who build up stock ahead of a rate change about the stockpiler rules in Article 11: without audited stock records the FTA can tax everything on the shelf. The refund route for non-registered exporters, revised from January 2026, is one we are testing for trading clients.
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