Stay updated with JAXA Chartered Accountants on FTA VATP045, covering Input VAT recovery and documentation requirements for imported goods in the UAE.
The UAE Federal Tax Authority (FTA) has issued a new Public Clarification, VATP045- Concerned Goods: Accounting for Output Tax, Issuing Tax Invoices, and Input Tax Recovery, providing necessary guidance on the VAT treatment of concerned goods imported into the UAE.
The Public Clarification, issued on August 26, 2026, addresses the applicable rules for output tax accounting, tax invoice issuance, and input VAT recovery in relation to Concerned Goods. Businesses should note that VATP045 relates to Concerned Goods imported on or before December 31, 2025. Following amendments to the UAE VAT Law effective January 1, 2026, the requirement for a taxable person to self-invoice for the import of Concerned Goods has been removed, subject to conditions.
For businesses importing goods into the UAE, understanding input VAT recovery for imported goods and documentation requirements is important for maintaining accurate VAT records and supporting compliance with FTA requirements. This guide from Jaxa Chartered Accountants, a leading VAT consultant and a UAE FTA tax agent with 19+ years of experience, explains the key points businesses should know about VATP045 and Input VAT recovery on relevant imports.
What are Concerned Goods Under UAE VAT?
Under the UAE VAT framework, Concerned Goods generally refer to goods imported by a taxable person where the goods would not have been exempt from VAT in the UAE if they had been supplied in the UAE.
The classification is determined by considering how the goods would be treated for VAT purposes if they were supplied within the UAE. This means the nature of the imported item alone does not determine whether it qualifies as Concerned Goods.
Accordingly,
- Goods that would be subject to VAT if supplied in the UAE may fall within the definition of Concerned Goods
- Goods that would be exempt from VAT if supplied in the UAE are generally outside the scope of Concerned Goods.
- The classification is relevant when determining the applicable VAT accounting, tax invoice, and input tax recovery requirements under the UAE VAT regulations.
UAE VAT Accounting & Reporting for Concerned Goods
Under Article 48(1) of the UAE VAT Law, a taxable person importing Concerned Goods for business purposes is required to account for the import as a taxable supply to itself.
- Self-Accounting for Output VAT: A taxable Person importing Concerned Goods for business purposes is treated as making a taxable supply to itself. Accordingly, the importer is required to account for the applicable output tax.
- Reconciliation in the VAT return: The value of the imported goods and corresponding Output Tax should be reconciled with the amounts pre-populated in Box 6 of the VAT Return for the relevant tax period.
- Adjustments for Import Arrangement: Where the imported goods were imported by another person on behalf of the taxable person, or where differences are identified in the pre-populated amounts, the relevant adjustment may need to be reported in Box 7.
UAE VAT Tax Invoice Requirements for Imported Concerned Goods
Under the UAE VAT provisions applicable to imports made on or before December 31, 2025, a taxable person importing Concerned Goods for business purposes was required to issue a Tax Invoice to itself and account for the corresponding Output tax under the self-supply treatment.
The FTA has clarified that a separate self-issued Tax Invoice may not be required where the importer maintains the prescribed supporting documents and correctly reports the imports in its UAE VAT return.
To support this treatment, the importer should:
- Obtain and retain the overseas supplier’s invoice
- Obtain and retain the customs declaration issued by the relevant Emirate Customs Department, showing the details and imported goods.
- Verify the VAT reported in Box 6 of the VAT Return or make the appropriate adjustment in Box 7, where applicable
Where the specified conditions are met, the taxable person is not required to obtain a separate administrative exception from the FTA to not issue a Tax Invoice to itself.
Businesses should ensure that the required supporting documents are available and properly maintained.
If the required supplier invoice and customs declaration are unavailable, businesses may retain the necessary records to support their VAT reporting and Input Tax recovery.
The clarification sets out the circumstances in which a separate self-issued Tax invoice is not required for the relevant historical imports and should not be interpreted as a general exemption from applicable VAT documentation requirements.
When can businesses claim input VAT on Imported Goods?
Businesses may recover Input VAT on imported Concerned goods in the first tax Period, or the immediately following tax period, in which the required supporting documents have been obtained and the consideration has been paid, subject to the applicable UAE VAT rules.
The relevant supporting documents may include the overseas supplier’s invoice and applicable customs declaration.
For Input Tax recovery purposes, consideration may be treated as paid where it has been paid or intended to be paid within six months of the agreed payment date, subject to the applicable UAE VAT regulations.
UAE VAT Changes for Concerned Goods from January 1, 2026
The VAT treatment of Concerned Goods changed with effect from January 1, 2026. Under the amended UAE VAT laws, Taxable Persons are no longer required to issue Tax Invoices to themselves for imports of Concerned Goods.
Accordingly, VATP045 applies to Concerned Goods imported on or before December 31, 2025 and provides clarification on the requirements applicable to those historical imports.
Businesses should distinguish the treatment based on the import date:
| Import date | VAT Treatment |
| On or before December | VATP045 provides guidance on self-invoice, Output tax, accounting, tax invoice requirements, and Input tax recovery. |
| From January 1, 2026 | A self-issued tax invoice is no longer required for imports of Concerned Goods under the amended VAT framework |
The import date is therefore a key consideration when determining the applicable VAT accounting and documentation requirements.
UAE VAT Compliance Checklist for Imported Concerned Goods
Businesses that imported Concerned Goods on or before December 31, 2025 should review their historical VAT treatment and supporting documents in light of the UAE FTA’s clarification.
Key areas to consider include:
- Review Imported Goods: Identify relevant Concerned Goods before January 1, 2026, and verify that the applicable VAT treatment was correctly applied.
- Verify Customs Documentation: Ensure that the relevant customs declarations are available and correspond with the underlying import transactions.
- Check Supplier Invoices: Retain the overseas supplier’s invoices and confirm that they contain sufficient information to support the import and related VAT treatment.
- Reconcile VAT return: Review import transactions against the amount reported or pre-populated in Box 6 of the VAT return and make any required adjustments in accordance with the applicable rules.
- Review Input VAT claims: Verify that Input VAT recovery is supported by the required documentation and the imported goods were used, or intended to be used, for making taxable supplies.
- Strengthen VAT records: Maintain a clear audit trail linking supplier invoices, customs declarations, VAT return entries, and Input VAT claims to support the business’s VAT position.
How Jaxa Auditors, a UAE FTA tax agent, helps?
The FTA Public Clarification VATP045 provides businesses with further guidance on the VAT treatment of Concerned Goods imported up to December 31, 2025, including documentation required for UAE VAT compliance and Input Tax recovery.
As a UAE FTA-approved tax agent with 19+ years of experience, Jaxa Chartered Accountants provides VAT consultancy services in the UAE, helping businesses review import VAT positions, assess input VAT recovery, identify documentation gaps, and strengthen compliance with UAE FTA regulations.
Jaxa can assist with:
- Reviewing the VAT treatment of imported Concerned Goods
- Assessing Input VAT recovery and supporting documentation
- Reviewing supplier invoices and customs declarations
- Reconciling import VAT with VAT return reporting
- Identifying potential VAT compliance gaps
- Providing practical guidance on applicable UAE FTA requirements
Other Jaxa services such as:
- UAE VAT consultancy and Compliance
- Corporate tax advisory and compliance
- UAE VAT registration and Deregistration
- VAT Return Preparation and filing
- Accounting and Bookkeeping Services in the UAE
- Audit and Assurance Services in the UAE
- Tax dispute and FTA Representation Support
For professional guidance on VATP045 and imported goods. Businesses can consult Jaxa’s UAE VAT specialist.
Get Expert UAE VAT Advice
Need help understanding UAE FTA VATP045 or reviewing your Input VAT recovery on imported goods?
Jaxa Auditors, a UAE FTA-approved tax agent with 19+ years of experience, can help you assess your VAT position and strengthen compliance.
Contact Jaxa’s UAE VAT consultants today for tailored guidance on the latest FTA requirements.
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