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December 05, 2025

GCC Tax Roundup – Key UAE & Bahrain Updates Businesses Must Not Miss (November 2025)

The final weeks of 2025 have brought several major regulatory updates across the UAE and Bahrain — from new Corporate Tax rules to updated penalty frameworks and revised Excise Tax provisions. As tax authorities continue to tighten compliance and digitalise their systems, businesses must stay ahead to avoid disruption.

Here’s your November roundup, curated by the team at Nishe.

UAE UPDATES

1. FTA Releases New Guide for Reactivating Deactivated Corporate Tax TRNs

The Federal Tax Authority has issued a new user manual explaining how businesses can reactivate Corporate Tax TRNs that were previously deactivated or deregistered.

This applies when a business:

  • Resumes operations
  • Becomes subject to Corporate Tax again
  • Had previously cancelled or suspended its TRN

The guide outlines step-by-step procedures, documentation, and timelines businesses must follow to ensure a compliant reactivation.

FTA Guide

2. Updated Administrative Penalties Framework (as amended to 2025)

Under Cabinet Decision No. 129 of 2025, the UAE has issued an updated and consolidated penalty regime covering:

  1. General Tax Procedures
  2. Excise Tax
  3. VAT

The updated framework modernises the penalty system by:

  • Introducing revised penalty amounts
  • Updating definitions
  • Creating a more proportionate and consistent compliance approach

Businesses should review the revised tables carefully to ensure they remain fully compliant.

Cabinet Decision (Consolidated Penalties)
 

3. Updated UAE Excise Tax Law — Federal Decree-Law No. 7 of 2017 (Amended)

The Ministry of Finance has published the latest amendments to the Excise Tax Law, including:

  • Revised calculation methods
  • Stricter pre-registration requirements
  • Enhanced controls for Designated Zones & Warehouse Keepers
  • New deductible and refundable tax clarifications
  • Extended audit timelines (up to 15 years for evasion or failure to register)
  • Higher tax rates — up to 200% of excise price or AED 100/unit

The message is clear: excise tax oversight is getting stricter, and compliance needs to be stronger.

Excise Law Updates

4. Cabinet Decision No. 106 of 2025 — New E-Invoicing Penalties

With e-invoicing deadlines approaching, the UAE has now issued penalties for non-compliance.

Key penalties include:

  • Failure to implement e-invoicing / appoint ASP: AED 5,000 per month
  • Not issuing/transmitting e-invoices: AED 100 per invoice (capped at AED 5,000/month)
  • Not issuing/transmitting credit notes: AED 100 per note (capped at AED 5,000/month)
  • Failure to report system failure: AED 1,000 per day
  • Failure to update ASP on registered data changes: AED 1,000 per day

The penalties become effective upon publication and signal the authority’s intention to enforce e-invoicing rigorously.

E-Invoicing Penalties

BAHRAIN UPDATE

1. Bahrain NBR Updates VAT Real Estate Guide (Version 1.5)

Bahrain has issued updates to its VAT Real Estate Guide, with new clarifications for Owners’ Associations (OAs).

Key takeaways:

  • Core OA activities (maintenance, common area services, legal representation) are non-economic → not subject to VAT.
  • Revenue-generating or commercial activities may require VAT registration.
  • Helps OAs understand when VAT applies — especially in mixed-use and large residential developments.

Bahrain Real Estate VAT Guide

Final Thoughts

As governments continue to modernise tax frameworks and enforce digital compliance, the businesses that act early — not late — will be the ones that stay ahead.

At Nishe, we help organisations across the GCC prepare for these changes with clarity, structure, and practical implementation support.

If you need help assessing your readiness or navigating any of these updates, our team is here to support you.

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