We’re not here to tell you to stop. AI tools are genuinely useful, and pretending otherwise would be dishonest. But there are things they do well, things they do badly, and a few things they can get catastrophically wrong when it comes to your UAE business finances. This is a practical guide to navigating all three.

What AI Tools Are Actually Good At

Used correctly, AI can save you real time. It’s excellent for explaining concepts, what is IFRS 15, how does the reverse charge mechanism work, what’s the difference between exempt and zero-rated supplies. It’s good at drafting templates, structuring spreadsheets, and helping you think through a problem before you bring it to your accountant.

Think of it as a very well-read research assistant. It has absorbed an enormous amount of accounting and tax literature. It can explain things clearly. It can point you in the right direction.

What it cannot do is apply that knowledge accurately to your specific business, your specific numbers, and your specific regulatory environment, particularly in the UAE, which is one of the fastest-moving tax jurisdictions in the world right now.

Where It Goes Wrong and Why It Matters

Here is the most important thing to understand about AI and UAE accounting: the models are trained on data with a cutoff date. The UAE introduced Corporate Tax in 2023. FTA Decision No. 13 on supplier verification took effect this week. IFRS 18 replaces IAS 1 in January 2027. The e-invoicing framework has changed multiple times this year alone.

An AI model may not know any of this. Or it may know some of it partially, and give you an answer that was correct six months ago and is wrong today.

It won’t tell you it’s uncertain. It will sound just as confident whether it’s right or wrong.

We’ve seen businesses make VAT recovery decisions, structure intercompany transactions, and interpret Corporate Tax obligations based on AI output that was plausible, well-written, and incorrect.

The Practical Rules We’d Suggest

Treat every AI output as a starting point, not a conclusion. If an AI tool tells you that something is VAT-exempt, or that a particular expense is deductible, that’s a hypothesis to verify, not an answer to act on. Cross-reference with FTA guidance, IFRS standards, or your accountant before making a decision.

Be especially cautious with numbers. AI tools can make arithmetic errors. They can misapply formulas. They can produce a beautifully formatted spreadsheet where the logic underneath is wrong. Always check the workings, not just the output.

Never paste sensitive financial data into a public AI tool. Your customers/suppliers names, bank account details, payroll figures, and commercial terms have no business in a public AI interface. Most AI tools are clear in their terms of service about how data is handled, but the safest position is simply not to put confidential information in.

Ask it to show its reasoning. If you ask an AI tool how it arrived at an answer, you’ll often spot where it’s made an assumption that doesn’t apply to your situation. This is one of the most useful habits you can develop when using these tools.

Know what you don’t know. The danger isn’t the question you ask AI. It’s the question you don’t know to ask. A good accountant brings pattern recognition built from hundreds of real situations. AI brings breadth without that depth of applied judgment.

Our View at Nishe

We believe in using technology, including AI, where it genuinely helps. We use it ourselves. But accounting is one of those fields where the cost of a confident wrong answer can be significant: a missed filing deadline, an incorrect VAT position, a CT return that doesn’t reflect the actual position of the business.

The UAE regulatory environment is moving faster than any AI model can keep up.

That’s not a reason to avoid these tools. It’s a reason to use them carefully, verify what they tell you, and know when the stakes are high enough to pick up the phone.

We’re always happy to be that phone call.

Get in touch with the Nishe team 

This is our monthly look back at what happened in September, what it means, and what you should be doing about it now.

The Big One: FTA Decision No. 13: Supplier Verification Before Input VAT

If there is one update from September that every VAT-registered business in the UAE needs to have properly absorbed, it is this one.

FTA Decision No. 13 of 2026 came into effect on 1 October. From this point forward, a valid tax invoice is no longer sufficient on its own to recover input VAT. Businesses must now verify the validity and integrity of their suppliers and their individual supplies before deducting input tax.

The UAE’s VAT system can be abused through false invoices, undeclared sales, and fictitious supplier relationships. Decision 13 is the FTA’s formal response, shifting some of the responsibility for supply chain integrity onto the buyer. It mirrors approaches already in place in other jurisdictions, but the UAE version is more detailed and more extensive than most.

The key thresholds:

Under AED 10,000 per supply: generally exempt from detailed verification, unless your total annual spend with that supplier exceeds AED 100,000. Once you cross that threshold with a supplier, the exemption disappears entirely for every invoice from them, however small.

Above AED 100,000 per supplier annually: full verification required. Identity documents. Place of business confirmation. Risk indicator assessment. And all of this must be refreshed every 12 months.

Above AED 375,000 per supplier annually: everything above, plus a written confirmation from a UAE bank that the supplier holds an account, and a documented review of their publicly available reputation.

Beyond the supplier checks, there are supply-level checks too, commercial rationale, pricing, licensed activity, and payment method, that apply to every individual invoice above the applicable threshold.

And one non-negotiable that applied from day one: every business must have a written policy in place, under Article 5(4) of the Decision, naming who implements, reviews, and supervises the verification process. It doesn’t get filed with the FTA. But if it doesn’t exist, that is itself a compliance failure.

We ran a webinar on this in September, the recording is on our YouTube channel and walks through exactly what you need to have in place: run your 12-month purchase report by supplier, identify who sits above AED 100,000 and AED 375,000, build the verification files, and make sure your policy document exists.

E-Invoicing: The Clock Is Now Running

The e-invoicing ASP appointment deadline, 30 October 2026,  is 29 days away as we write this.

For businesses above AED 50 million in annual revenue, that is the confirmed deadline to appoint an Accredited Service Provider through the MRI tax portal. The go-live date of 1 January 2027 has not changed and will not change.

Appointing your ASP is not the hard part. Everything that needs to happen between appointment and go-live: data remediation, system integration, workflow redesign, end-to-end testing takes time that the window between 30 October and 1 January does not generously provide.

The businesses that will go live smoothly in January are the ones who started their data assessment and ASP evaluation months ago. If that isn’t where you are, you are not yet in a position where speed alone fixes the problem. You need the right support.

If you are above the revenue threshold and have not yet begun your readiness programme, contact us this week. We have been working through e-invoicing implementations with UAE businesses all year. We know where the time goes and where the problems hide.

Small Business Relief Extended to 31 December 2029

The welcome news from September: Ministerial Decision No. 131 of 2026 extends the Small Business Relief threshold to 31 December 2029.

Eligible UAE resident businesses with gross revenue of AED 3 million or less continue to benefit from 0% Corporate Tax and are exempt from transfer pricing documentation requirements throughout the relief period.

Three more years of significantly simplified Corporate Tax compliance for qualifying businesses: more time, more headroom, more focus on growth.

Two things we always remind clients about SBR:

It must be actively elected in your Corporate Tax return each period. It is not applied automatically. If you have not elected it and you qualify, you have been leaving a benefit unclaimed.

And eligibility must be assessed properly. Businesses that are part of a multinational enterprise group or a UAE large business group do not qualify, regardless of their own revenue. If you have not formally reviewed your eligibility, do that now, particularly given the extension makes this benefit worth claiming correctly for the next three years.

Top-Up Tax: New Registration Deadlines and Guides

September brought important formalisation of the registration and deregistration framework for the Qualified Domestic Minimum Top-up Tax, through FTA Decision No. 12 of 2026.

For MNE groups with annual consolidated revenues of EUR 750 million or more, the registration deadline for entities with fiscal years ending before 30 April 2026 is 30 November 2026. That is eight weeks away. The FTA also published two new substantive guides in September, one on excluded entities and investment entities, one on scope and registration, both of which should form part of any MNE group’s compliance assessment.

Deregistration obligations have also been clarified. Entities that ceased to exist before 30 June 2026 must deregister by 31 December 2026. Where a Domestic Designated Filing Entity is appointed, it carries the responsibility for all registrations and notifications on behalf of group members.

If your group is in scope and you have not yet completed your registration assessment, November 30 is not far away.

Record-Keeping Rules: Already In Effect

FTA Decision No. 4 of 2026 has been in effect since 30 July, but September is a good moment to make sure your business has genuinely reviewed its document management practices against the new requirements, not just noted that the decision exists.

The specific points that catch businesses out: partial document scanning is explicitly prohibited. Every document must be retained in full, in original page order, and be clearly legible. The FTA must be granted access to all records on request, including passwords and encryption keys for electronic systems. And using a third-party provider to manage your records does not transfer the legal compliance responsibility; it remains with you.

If your record-keeping processes have not been reviewed against these requirements, that review is overdue.

What to Focus on in October

The first week of October should look like this for most UAE finance teams:

If you are above AED 50 million in revenue and your e-invoicing programme is not yet underway, make that call today. The 30 October appointment deadline is the first milestone; the real work starts the moment you appoint, and the clock to January begins properly.

If you are VAT-registered and have not yet run your supplier purchase analysis for Decision 13, do that this week. The decision is live. Build your verification files starting with your highest-spend suppliers.

If you are part of an MNE group within Top-up Tax scope, confirm your registration timeline against the 30 November deadline and review the new FTA guides.

If your business qualifies for Small Business Relief and you have not been formally electing it, speak to your accountant about correcting that and confirming you remain eligible under the extended framework.

At Nishe, we are working alongside UAE businesses on all of this not as advisors handing over reports, but as a team that gets into the detail alongside you.

If your Q4 compliance calendar feels like it is carrying more than one team can manage, we would love to have a conversation about how we can help.

A valid tax invoice used to be enough.

From 1 October 2026, it isn’t.

FTA Decision No. 13 of 2026 introduces a new layer of obligation for every taxable person claiming input VAT in the UAE. Before you deduct input tax, you now need to verify the validity and integrity of your suppliers and your supplies, and document that you did it.

This isn’t a bureaucratic technicality. The UAE tax system is maturing, and this decision is part of a deliberate effort to close the loopholes that enable VAT fraud, false invoices, undeclared sales, fictitious suppliers, and unsupported VAT claims. It mirrors approaches already in place in other jurisdictions, including HMRC’s reasonable commercial checks framework in the UK. But the UAE version is more extensive, and it puts significant responsibility on the buyer.

Here’s everything you need to understand, and what to do about it.

Why This Decision Matters

To understand the change, it helps to understand what problem it’s solving.

VAT is designed so that businesses collect tax on their sales, recover tax on their purchases, and pay the FTA the net difference. But the system can be abused. A supplier declares sales of AED 50,000 on which they’ve collected VAT, but only declares AED 20,000 in their VAT return, keeping the rest. Their customer meanwhile claims input VAT based on the full invoice. The result: VAT has been collected but not paid to the government.

This is what tax evasion in the supply chain looks like. And until now, a buyer who had a valid tax invoice had very limited exposure to someone else’s evasion.

Decision 13 changes that. Under the updated Article 54 of the VAT Law, the FTA can now deny input VAT recovery if a purchase is connected to tax evasion and the buyer knew, or should have known, about it.

That second limb is what makes this significant. You don’t have to have participated in fraud. You just have to have failed to take the steps a reasonable business would take to identify that something was wrong.

What Was Required Before, and What’s Changed

Previously, three conditions formed the foundation of input VAT recovery:

A compliant tax invoice. Payment or an intention to pay. A genuine business expense with no personal usage element.

These three conditions haven’t been removed. But Decision 13 adds a new layer on top of them:

A valid tax invoice is no longer enough. You must also verify your supplier’s identity documents. You must refresh these checks annually. You must assess each individual supply, not just the supplier relationship. There are monetary thresholds that determine the extent of the checks required. Cash payments need a documented commercial reason. And a written internal policy must exist naming who performs, reviews, and supervises the verification process.

The Three Thresholds, Explained Simply

Three numbers are central to this Decision. Understanding how they interact is the most important practical exercise any VAT-registered business can do right now.

AED 10,000 per supply (VAT-exclusive)

If the value of a single supply, excluding VAT, is below AED 10,000, that supply is generally exempt from the detailed verification checks on its own.

But this exemption has a catch.

AED 100,000 per supplier (rolling 12 months)

If your total spend with a supplier over any rolling 12-month period reaches or exceeds AED 100,000, the AED 10,000 exemption disappears entirely for that supplier. Every supply from that supplier, however small each individual invoice is, now requires the full verification checks.

This is the threshold most businesses will underestimate. A supplier you pay AED 8,000 a month, AED 96,000 per year, sits just below. One additional small purchase pushes them over, and suddenly every invoice from them is in scope, retroactively.

AED 375,000 per supplier (rolling 12 months)

If your spend with a single supplier exceeds AED 375,000 over the rolling 12-month period, two additional requirements apply on top of everything in the middle tier: a written bank confirmation that the supplier holds a UAE bank account, and a documented review of the supplier’s public reputation.

On the bank confirmation: the Decision specifies that this letter does not need to be addressed to your company. An IBAN verification letter from the supplier’s bank, clearly showing the account details to which you make payment, can satisfy this requirement in practice.

On the reputation review: newspaper coverage, media checks, website review, and online presence are all reasonable approaches. The aim is to identify publicly available negative signals, litigation, regulatory action, and reputational issues that a reasonable business would have found.

How to Verify Your Suppliers

Once you’ve mapped which suppliers fall above AED 100,000 and AED 375,000, the verification work falls into two categories: supplier checks and supply checks.

Supplier Checks, Who You’re Buying From

For a natural person supplier:
Obtain a copy of their Emirates ID or passport. Meet the supplier, in person or virtually, before the supply is made. This meeting requirement is specific to natural persons. It doesn’t apply to companies.

For a legal person supplier:
Verify their company documents through official databases. Obtain the certificate of incorporation and confirm that the entity details, name, address, employees are consistent and accurate. Verify the identity of the director, agent, or employee authorised to represent the supplier.

Place of business verification:
Confirm the supplier has a genuine place of business, either electronically or by a field visit, and that it’s consistent with what they actually do. If a supplier tells you they’re in electronics manufacturing and the address is a consumer goods factory, that’s a red flag worth documenting. A mismatch between the declared activity and the physical premises is exactly the kind of signal this check is designed to surface.

Risk indicators to watch:
Three specific indicators are called out in the Decision. If any of these are present, you need a documented and justified explanation on file:

• The supplier’s address has changed more than twice in the previous 12 months
• Key employees or managers have changed more than twice in the previous 12 months
• Transactions are disproportionate or unexpected given the supplier’s size and history

Spotting a risk indicator doesn’t mean you have to stop dealing with the supplier. It means you need to investigate and document a reasonable explanation.

Supply Checks, What You’re Buying

For every individual supply above the applicable threshold, you need to satisfy yourself about the transaction itself, not just the supplier.

Commercial rationale: Is there a genuine commercial reason for this purchase? Is the supplier’s engagement based on real business need? This is particularly important in procurement and accounts payable processes; anyone bringing suppliers into the business needs to understand the new standard of scrutiny that applies.

Payment method: Payments should be electronic wherever possible. Cash payments require a documented commercial reason, must be verifiable, and must fall within applicable legal thresholds. Third-party and overseas payments need a clear rationale; the days of paying a supplier’s agent and treating it as equivalent to paying the supplier directly are over, at least without proper documentation.

Prices and margins: The prices you pay should not be unjustifiably different from market norms. Goods or services must match the supplier’s licensed activity. For goods, you should verify authenticity, origin, and the supplier’s right to dispose of them. Where the supplier is an intermediary, there should be a documented commercial rationale for their role.

One practical approach to price verification: obtain quotations from multiple suppliers, or check publicly available market prices for comparable goods or services online. For imported goods, customs documentation and detailed goods listings from the supplier are particularly important.

The FTA has signalled that more detailed guidance is expected, similar to how public clarifications developed over time for zero-rated supplies of goods and services. When that guidance arrives, it will likely standardise the evidentiary requirements by industry and transaction type. Until then, documented judgment calls based on the current Decision are the right approach.

What Documentation Must You Keep?

Running the checks is only half the job. The other half is proving you ran them.

Supplier verification files:
For every supplier above the applicable threshold, maintain a file containing their identity documents, company incorporation records, place of business confirmation, risk indicator assessment and any explanations, and, for suppliers above AED 375,000, the bank confirmation and reputation review.

This file needs to be established on your first dealing with the supplier, and refreshed every 12 months. A 12-month verification cycle isn’t optional, the requirement recurs annually regardless of how long the relationship has existed.

Supply-level documentation:
For each supply above the threshold, document the commercial rationale, confirm the payment method is appropriate, and note any checks on pricing, licensed activity, and authenticity of goods. This should be built into your AP process rather than treated as a separate exercise.

The written verification policy:
Article 5(4) of Decision 13 requires every business to have a written policy in place before the Decision takes effect. This policy must name who implements the verification procedures, who reviews them, and who supervises them, with clear powers and responsibilities assigned.

This document is not filed with the FTA. But it must exist and be maintained with your tax records. It is the first thing an FTA officer can request to see, and the absence of it is itself a compliance failure.

Practical Steps to Take Right Now

Step 1: Map your active suppliers
Pull a rolling 12-month purchase report by supplier. Identify everyone above AED 100,000 and AED 375,000. This is your starting point and it determines the scope of everything that follows. Note: the look-back from 1 October already extends to October 2025, the data you need is historical, not future.

Step 2: Build supplier verification files
For every supplier above AED 100,000: identity documents, company records, place of business confirmation, risk indicator notes. For every supplier above AED 375,000: add the bank confirmation and reputation review. Start with your highest-spend suppliers and work down.

Step 3: Introduce a 12-month refresh cycle
One-off verification isn’t enough. Build a recurring annual review into your supplier management process. Systems that flag document expiry, trade licences, Emirates IDs, passports, are particularly useful here given that the FTA is already tightening its stance on expired documents in registration and deregistration processes.

Step 4: Embed supply-level checks into your AP process
Commercial rationale, payment method, pricing, and licensed activity checks need to become part of the standard invoice approval workflow. They won’t get done consistently if they sit outside the existing process.

Step 5: Draft and approve the written policy
Name the right people. Match the document to how your procurement and finance functions actually operate. A template policy with the wrong names or the wrong process is worse than no policy at all, if it doesn’t reflect how the business actually works, it won’t survive FTA scrutiny.

Step 6: Move cash payments to electronic methods
Or, where cash remains necessary, document the commercial reason. This is particularly relevant for businesses with significant petty cash purchasing.

A Note on Scope

This applies to every taxable person claiming input VAT, with no sector exceptions and no free zone carve-out. It also applies to foreign suppliers, because the Decision’s definition of input tax specifically includes tax due when conducting an import. For reverse charge supplies from overseas suppliers, the verification checks do apply is the understanding.

There are no specific financial penalties attached to Decision 13 itself. The consequence of non-compliance is the denial of input VAT recovery, which, for businesses with significant supplier spend, is materially punitive in its own right.

How Nishe Can Help

This is detailed, judgment-based compliance work that requires someone to actually sit down with your supplier and purchase data, understand your procurement processes, and build a verification framework that fits how your business actually operates.

We can help with the rolling 12-month supplier analysis, drafting the Article 5(4) written policy, reviewing your existing supplier files against the new requirements, and building the supply-level checks into your AP process.

Watch the full webinar recording on our YouTube channel

August 2026 arrived with a cluster of regulatory changes that affect a wide range of UAE businesses, from multinationals managing Top-up Tax obligations to small businesses claiming relief, and from tobacco importers to every VAT-registered business in the country.

None of these are distant future concerns. Several are live this month or within weeks. Here’s the breakdown.

1. Excise Tax Minimum Prices for Tobacco and E-Smoking Products, Live from 1 September 2026

Cabinet Decision No. 137 of 2026 introduces minimum excise prices for tobacco and electronic smoking products, effective today.

The minimum prices:

Cigarettes: AED 0.40 per cigarette. Water pipe tobacco, ready-to-use tobacco, and similar products: AED 0.10 per gram. Liquids used in electronic smoking devices, whether or not they contain nicotine: AED 1 per millilitre.

The previous Cabinet Decision No. 55 of 2019 on excise prices for tobacco products is repealed. The excise price will otherwise continue to be determined under the methodology in Cabinet Decision No. 197 of 2025, subject to these new minimum floor prices.

What this means in practice: The minimum price acts as a floor. Where the calculated excise price under the standard methodology falls below these minimums, the minimum price applies instead. Businesses in the tobacco supply chain- importers, distributors, and retailers- need to review their current excise calculations and pricing structures against these floors immediately.

What to do: If your business handles any of these product categories, review your excise tax calculations and pricing as a matter of urgency. This is live from today.

2. Updated Record-Keeping Requirements, FTA Decision No. 4 of 2026 (Effective 30 July 2026)

The FTA issued Decision No. 4 of 2026 in June, with effect from 30 July 2026. This updates the rules for maintaining and preserving accounting records and commercial books for tax compliance purposes, and the requirements are more specific than the previous framework.

What’s required:

Records must be complete and identical to the originals. Electronic copies and photocopies are permitted, but must include all pages in the original order and be of sufficient quality to be clearly legible.

Partial scanning is explicitly prohibited. You cannot scan only the pages you think matter; the full document must be retained.

The FTA must be granted access to all records on request, including passwords and encryption keys for electronic systems. If you use a third party to maintain your records, you remain legally responsible for compliance and record safety. The decision of convenience doesn’t transfer the legal obligation.

Why this is more significant than it sounds:

Most businesses assume their record-keeping is adequate. The specific prohibition on partial scanning, and the explicit requirement for original-order retention, will catch businesses that have been scanning selected pages, compressing documents, or keeping only summary records. An FTA audit request that can’t be satisfied because records are incomplete or partially retained is a material compliance failure.

What to do: Review your current record-keeping and document management processes against these requirements. If you use a third-party accounting or document management provider, confirm in writing that their practices comply with this Decision.

3. Top-up Tax Registration, FTA Decision No. 12 of 2026 (Key Deadline: 30 November 2026)

FTA Decision No. 12 of 2026, issued 16 July 2026 and effective for fiscal years starting on or after 1 January 2025, establishes the registration and deregistration timelines for entities subject to the Qualified Domestic Minimum Top-up Tax.

This applies to multinational enterprise groups operating in the UAE with annual consolidated revenues of EUR 750 million or more.

Registration timeline:

Entities in scope must register with the FTA within 7 months after the end of their first fiscal year in scope. For entities with a fiscal year ending before 30 April 2026, registration must be completed by 30 November 2026. That deadline is 13 weeks away.

Deregistration timeline:

Entities must apply for deregistration within 6 months of ceasing to exist or leaving an MNE group. Entities that ceased to exist before 30 June 2026 must deregister by 31 December 2026. Deregistration is only possible after all Top-up Tax liabilities and returns are settled. The FTA retains the discretion to deregister entities at its own initiative if the requirements are met but no application has been submitted.

Out-of-scope notifications:

Where an entity or group falls out of scope, a notification must be submitted within 6 months from the end of the relevant fiscal year. That notification remains valid for up to 5 years. If the entity comes back into scope, an in-scope notification is required within 7 months. After 5 consecutive years out of scope, deregistration is required within 6 months, unless the entity re-enters scope.

Designated Filing Entities:

Where a Domestic Designated Filing Entity is appointed, it is responsible for all registrations, deregistrations, and notifications on behalf of the group members.

What to do: MNE groups with UAE operations should review their group structure and fiscal year-end dates immediately. The November 30 registration deadline for entities with early fiscal year-ends is approaching fast. If a Designated Filing Entity is in place, confirm it has the necessary information to meet the registration requirements on behalf of all group members.

4. Top-up Tax Guides, Excluded Entities and Scope & Registration

The FTA has issued two new Top-up Tax guides alongside the registration decision:

TTGEIE1, Excluded Entities and Investment Entities
This guide covers the definition of Excluded Entities under the DMTT legislation, the election not to treat certain entities as excluded, the definition of Investment Entities, and the practical implications of each status. Not all entities within an MNE group are automatically in scope, understanding the excluded entity categories is an important first step before completing the registration assessment.

TTGREG1, Scope and Registration
This guide explains the conditions that bring an MNE group within scope of the DMTT legislation, the types of entities that are and are not subject to Top-up Tax, and the full registration process and timelines.

What to do: If your business is part of an MNE group with UAE operations, both guides should be reviewed as part of your registration assessment. The excluded entity determination in particular should be documented, it is not a position you want to arrive at informally.

5. FTA Decision No. 13 of 2026, Supplier Verification Before Input VAT Deduction (Effective 1 October 2026)

We have covered this in detail in a dedicated post, but given the October 1 effective date and the significance of the change, it warrants including here.

FTA Decision No. 13 of 2026 requires all UAE VAT-registered businesses to complete specific verification checks on suppliers and individual supplies before deducting input VAT. It applies from 1 October 2026 with no sector exceptions.

The three thresholds:

Supplies under AED 10,000 (VAT-exclusive), generally exempt, unless total annual spend with that supplier exceeds AED 100,000.

Suppliers above AED 100,000 annually, full verification required: identity, place of business, and risk indicators. The AED 10,000 exemption disappears for that supplier entirely.

Suppliers above AED 375,000 annually, all of the above, plus a written UAE bank confirmation and a documented review of publicly available information about the supplier.

The one document every business must have by 1 October:

A written policy, required under Article 5(4) of the Decision, naming who implements, reviews, and supervises the verification procedures. It doesn’t get filed with the FTA, but it must exist and be maintained with your tax records.

What to do: Run a rolling 12-month purchase report by supplier this week. The look-back on 1 October already reaches October 2025. Identify your AED 100,000 and AED 375,000 suppliers. Build the verification files. Write the policy. Four weeks is not much time.

6. Procedures for Seized and Abandoned Goods, FTA Decision No. 7 of 2026

FTA Decision No. 7 of 2026, effective 30 July 2026, establishes formal procedures for the storage, sale, and revenue allocation of seized or abandoned goods, particularly those that are perishable, subject to leakage, or may endanger other goods or facilities.

The key practical points: seized goods may be sold by public auction if perishable, dangerous, or unclaimed after outstanding liabilities are settled. Sales require a committee decision and, where goods are under investigation, approval from the relevant legal authorities. Auction proceeds are applied first to auction and storage costs, then to outstanding taxes and penalties, with any remainder either credited to the owner’s tax account or transferred to FTA revenues where rights are waived.

Who this matters for: Businesses operating in import, distribution, or excisable goods categories where seizure risk is a genuine operational possibility. For most businesses this is background information, but for those in the relevant sectors, understanding the procedure before it applies to you is better than encountering it for the first time under pressure.

7. VAT on Concerned Goods, Public Clarification VATP045

The FTA has issued Public Clarification VATP045, addressing the VAT treatment of “Concerned Goods” imported into the UAE on or before 31 December 2025.

A VAT-registered business importing Concerned Goods is required to account for output tax and issue a self-billed tax invoice in respect of the import, unless they obtained an administrative exception from the FTA. Input tax can be recovered to the extent the goods were acquired to make taxable supplies, provided the business is VAT-registered and retains the supporting documents: the supplier’s invoice and a declaration from the relevant Emirate Customs Department.

What to do: If your business imported Concerned Goods before 1 January 2026 and hasn’t reviewed its output tax accounting and self-billing obligations under this clarification, do so now. Input tax recovery depends on having the right documentation in place, retroactively assembling it is significantly harder than maintaining it at the time.

8. Small Business Relief Extended to 31 December 2029

The good news in this round: Ministerial Decision No. 131 of 2026 officially extends Small Business Relief to 31 December 2029.

Eligible resident businesses with gross revenue of AED 3 million or less continue to benefit from 0% Corporate Tax and are exempt from transfer pricing documentation requirements for the relief period.

This is a meaningful extension, three more years of significantly simplified Corporate Tax compliance for qualifying businesses.

The important details to remember:

SBR must be actively elected in your Corporate Tax return. It is not applied automatically. Businesses that are part of a multinational group or UAE large business group do not qualify regardless of revenue. And electing SBR means you are treated as having no taxable income for that period, which simplifies compliance but also has implications for how certain elections and loss carry-forward rules apply.

What to do: If your business has revenue below AED 3 million and you haven’t yet assessed whether you qualify, this extension makes that assessment worth doing now. If you’ve been electing SBR without formally reviewing the eligibility conditions each year, it’s worth confirming that your position remains correct.

Key Actions & Upcoming Deadlines

Immediate, live from 1 September:
Excise tax minimum prices, review calculations and pricing for tobacco and e-smoking products.

Already in effect, review now:
Record-keeping requirements, review document management practices against FTA Decision No. 4 of 2026.
Concerned Goods VAT, review output tax accounting and documentation for pre-2026 imports.

Before 1 October:
Supplier verification, run your purchase report, build supplier files, write the Article 5(4) policy.

Before 30 November:
Top-up Tax registration, MNE groups with fiscal years ending before 30 April 2026 must register.

Before 31 December:
Top-up Tax deregistration, entities that ceased to exist before 30 June 2026.

Ongoing:
Small Business Relief, confirm eligibility and elect correctly in your CT return.

How Nishe Can Help

These updates span excise tax, VAT, Corporate Tax, Top-up Tax, and record-keeping obligations. If any of them raises a question about your specific position, or if your Q4 compliance calendar is starting to feel overwhelming, we’re here to help.

No lengthy engagement before we’ve understood your situation. Just a practical conversation about where you are and what you need.

Get in touch with the Nishe team

The Federal Tax Authority has issued multiple new directives, public clarifications, and updated guides covering everything from VAT on education and judicial services to digital currency reporting, life insurance fees, deemed supplies, transfer pricing adjustments, and free zone compliance. There are also important updates from Saudi Arabia and Bahrain.

This post covers everything that matters, what’s changed, what it means for your business, and what to do next.

UAE VAT Updates

1. VAT and Education Services, New Comprehensive Guide (VATGED1)

The FTA has released a comprehensive guide on the VAT treatment of educational services and related goods. This is important for any business that provides, supports, or purchases educational services, and for schools, universities, nurseries, and other educational institutions directly.

The core principle: not all education is zero-rated

Zero-rated treatment only applies where two conditions are met simultaneously. The institution must be a Qualifying Educational Institution, recognised by the relevant government authority, and for higher education, government-owned or majority government-funded. And the services must be delivered as part of a Qualifying Curriculum.

Where either condition isn’t met, private tutoring, non-accredited courses, for example, the standard 5% VAT rate applies.

Related goods and services

Items directly related to zero-rated education may also be zero-rated, lab materials and required reading being typical examples. However, the following are explicitly subject to 5% VAT regardless of context: uniforms, electronic devices, food, and extracurricular activities with additional fees.

The nuances worth knowing:

Field trips are zero-rated if directly related to the curriculum and not mainly recreational; the recreational purpose test matters here. Graduation fees are zero-rated if linked to a qualifying programme. Special needs support is zero-rated if directly related to the curriculum and approved by authorities.

Student and staff accommodation can be exempt or standard-rated depending on what services are bundled with it. Distance learning VAT treatment depends on the level of automation and human involvement; automated electronic services may be taxed based on where they are consumed.

Scholarships are treated as discounts, meaning VAT applies to the reduced fee. Grants and donations are outside the scope of VAT where the donor receives no direct benefit from the transaction.

What to do: Educational institutions should review their current VAT treatment of all supplies against this guide. The line between zero-rated, exempt, and standard-rated is more detailed than many institutions currently apply in practice.

2. Private Tax Clarifications, Updated Process (July 2026)

The FTA has updated its guidance on how to submit private tax clarifications, the mechanism that allows taxpayers to seek official, binding guidance on specific tax matters that aren’t already addressed in public FTA materials.

This is a genuinely useful tool that is underused by most UAE businesses.

What taxes are covered: Excise Tax, VAT, Corporate Tax, and the new Top-up Tax (effective January 2025).

Who can apply: Taxpayers, Tax Groups (via the representative member), Tax Agents, and Legal Representatives. For Corporate Tax and Top-up Tax clarifications, the applicant generally needs to be registered for those taxes.

What qualifies: The request must relate to a genuine uncertainty on a specific tax matter affecting the applicant. It must be specific, supported by relevant documents, and not already addressed in existing FTA guidance. Requests for hypothetical scenarios, matters under audit, or administrative exceptions are not accepted.

The process: All requests go through the EmaraTax portal, with a detailed cover letter and supporting documents. Fees are AED 1,500 for a single tax or AED 2,250 for multiple taxes. The FTA has 60 business days to respond, in English or Arabic as requested.

What a clarification gives you: A binding interpretation, but only for the applicant and the specific facts provided. It cannot be used by other parties and is not subject to dispute resolution. If circumstances change, a new request can be submitted.

Common errors to avoid: Submitting on behalf of third parties, incomplete technical analysis, asking for confirmation of eligibility rather than clarifying a genuine uncertainty, and submitting requests on matters already addressed in public guidance.

What to do: If your business has unresolved tax positions where the correct treatment is genuinely uncertain, a private clarification is worth considering, particularly for matters that have a material impact and where public guidance doesn’t provide a clear answer.

3. Judicial Expert Services Now Subject to VAT

The FTA has issued Directive on Tax Transactions No. 1 of 2026, clarifying that services provided by court-appointed judicial experts are taxable supplies for VAT purposes.

Court-appointed judicial experts, whether individuals or legal entities registered with the Ministry of Justice, local judicial authorities, or arbitration centres, are considered to be carrying on a business when they provide expert services. The fees they receive are consideration for a taxable supply of services.

This means judicial experts who meet the VAT registration threshold must register and comply with all VAT obligations. Importantly, receiving payment from a government entity does not change the VAT treatment, the supply is taxable regardless of who the customer is.

What to do: If you provide judicial expert services and are not currently VAT registered, review whether your annual fees exceed the registration threshold. If they do, registration is now required.

4. VAT Adjustments When Leaving a Tax Group, New Directive (From 1 August 2026)

The FTA has clarified the VAT treatment when a business exits a VAT Group but remains VAT-registered. This applies from 1 August 2026.

When a business leaves a VAT Group, it becomes responsible for reporting adjustments in its own VAT returns for transactions that were previously declared by the Tax Group. This covers credit notes, discounts, returns, and changes to previously claimed input VAT.

The departing entity must maintain records that clearly link these adjustments to transactions originally reported under the former VAT Group. Without that documentation, the adjustments cannot be properly substantiated.

What to do: If your business has recently left, or is planning to leave, a VAT Group, ensure your record-keeping is structured to allow these historical adjustments to be accurately reported. This is an administrative process with real compliance consequences, documentation is everything here.

5. Digital Currency Conversion for VAT Reporting, New Standard Method

The FTA has issued Directive No. 3 of 2026, introducing a standardised method for converting digital currency values into UAE Dirhams for VAT reporting.

This applies to supplies of digital currency and to supplies of goods and services where consideration is received in digital currency.

The method: Taxable persons must select three FTA-approved centralised digital currency exchange platforms and use the same three platforms consistently throughout the calendar year. The AED value is determined using the average exchange rate published by those three platforms at the time of the supply or receipt of consideration.

Records of the exchange rates used from each platform must be retained.

The FTA will publish the approved list of exchange platforms and further guidance for cases where rates are unavailable across three approved platforms.

What to do: If your business accepts digital currency as consideration for any supplies, you need to select your three approved platforms and establish a consistent, documented process for applying this conversion method in your VAT returns.

6. VAT Treatment of Life Insurance Fees and Charges

Directive No. 4 of 2026 clarifies when fees and charges associated with life insurance and reinsurance contracts qualify for the VAT exemption.

The exemption applies where fees and charges are necessary and directly connected to providing or transferring a life insurance or life reinsurance contract, but only where those fees are included within the insurance premium and no separate consideration is charged.

Fees that relate to the management, operation, or administration of the life insurance contract may be eligible for the exemption, subject to those conditions being met. Services that are independent in nature or charged separately are treated as separate taxable supplies.

What to do: Insurance companies and financial services businesses should review their current fee structures against this directive. The boundary between exempt and taxable treatment depends on whether fees are bundled within the premium or charged separately, and the facts of each case matter.

7. Valuation of Deemed Supplies of Services, Standard Methodology Introduced

Directive No. 5 of 2026 prescribes a standard methodology for determining the value of deemed supplies of services for VAT purposes.

Under this methodology, the value must be based on the costs incurred on which input VAT was recovered, not the full market value of the service. The calculation works as follows:

First, determine the open market value of the service (or a comparable service where necessary). Second, remove the profit element using the previous year’s net profit margin, or the sector average where that isn’t available, to estimate total cost. Third, calculate the proportion of total costs on which input VAT was incurred. Fourth, apply that percentage to the estimated total cost to arrive at the value of the deemed supply.

What to do: Businesses making deemed supplies of services should ensure their VAT return calculations align with this methodology. If you have been using market value as the basis, your approach needs to change.

UAE Corporate Tax Updates

8. Transfer Pricing Downward Adjustments, FTA Clarification (CTP011)

The FTA has issued Public Clarification CTP011, providing guidance on downward transfer pricing adjustments under the arm’s length principle.

The key practical point: downward adjustments, those that reduce taxable income, can be made without prior FTA approval. The UAE Corporate Tax regime operates on a self-assessment basis, so businesses can make these adjustments themselves in their CT return.

However, every downward adjustment must be disclosed in the Corporate Tax Return, regardless of its value or nature.

The documentation requirements are specific and must be maintained:

The rationale for the adjustment. An arm’s length analysis with benchmarking data. A reconciliation between the financial statements and the tax return values. Evidence of corresponding adjustments by the related party, where applicable.

This clarification covers downward adjustments under Article 34(1) of the Corporate Tax Law only. It does not address corresponding adjustments under Articles 34(10) and 34(11).

What to do: If your business has related-party transactions that are not recorded at arm’s length in your accounts, assess whether a downward adjustment is appropriate and ensure the full documentation package is in place before the CT return is filed.

9. AT1 Instrument Payments by Banks, Tax Treatment (CTP012)

The FTA has issued Public Clarification CTP012, clarifying that payments made by banks on Additional Tier 1 (AT1) capital instruments are not deductible for Corporate Tax purposes if they are not recognised in accounting income.

Where AT1 instruments are classified as equity under IFRS, which is the typical treatment, related dividend or coupon payments are made from retained earnings and do not pass through the profit and loss account. Since Corporate Tax starts from accounting income, payments that don’t appear in profit or loss cannot be claimed as deductible expenses.

This clarification applies only to the issuing bank. It does not address the tax treatment of AT1 instruments from the holder’s perspective.

What to do: Banks and financial institutions with AT1 instruments should review the accounting classification and ensure their CT return treatment aligns with this clarification.

10. Free Zone Compliance, New Requirements for QFZPs in Distribution Activities (FTA Decision No. 6 of 2026)

This is one of the most significant updates for free zone businesses in this round.

The FTA has issued Decision No. 6 of 2026, introducing additional compliance procedures for Qualifying Free Zone Persons engaged in the distribution of goods or materials in or from Designated Zones. It applies to tax periods from 1 January 2026.

The core new requirement: QFZPs must obtain an Agreed-Upon Procedures (AUP) report from an independent external auditor, prepared under International Standard on Related Services 4400. This report verifies compliance with qualifying activity requirements and must be submitted within 30 days after the deadline for filing the relevant Corporate Tax return.

What the auditor will verify:

That customers are resellers, evidenced by business licences, signed declarations, and sales agreements. That goods imported into the UAE entered through a Designated Zone, evidenced by import declarations and shipping documents. That internal records for goods movement and storage are properly maintained.

The auditor reviews a sample of customer and import records, focusing on those with the highest transaction values. The sample size is determined by a specific formula with a 10% margin of error.

Non-compliance consequence: Failure to submit the required report means the QFZP will not be considered compliant for tax purposes, which puts the preferential free zone tax treatment at risk.

What to do: If your business is a QFZP engaged in distribution activities, start organising your customer and import documentation now. Engaging your external auditor early to understand the AUP requirements and what records they’ll need is strongly recommended, this is not something to address in the month the report is due.

Saudi Arabia Update

11. ZATCA, 25th Wave of E-Invoicing Integration Phase

ZATCA has announced the 25th Wave of its E-Invoicing Integration Phase (Phase Two), targeting businesses with VAT-taxable revenues exceeding SAR 187,500 in any of the years 2022, 2023, 2024, or 2025.

Affected businesses must integrate their e-invoicing solutions with the Fatoora Platform by 1 February 2027. Phase Two requires system integration, electronic format invoicing, and additional mandatory invoice fields.

ZATCA will notify affected businesses directly, with at least six months’ notice before the integration deadline.

What to do: If your business has KSA operations and VAT-taxable revenues above the threshold in any of the relevant years, check whether you’ve received or expect to receive a ZATCA notification. If you haven’t yet integrated with Fatoora, that process needs to begin now, six months is not a long runway for a full system integration.

Bahrain Update

12. VAT General Guide, Key Updates (July 2026)

Bahrain’s VAT General Guide has been updated with two notable changes.

Section 10.3 introduces enhanced requirements for VAT invoices, particularly around the need for clear and detailed descriptions of supplied goods or services. For construction-related supplies specifically, the building permit number must now be included on the invoice.

Section 11.8.4 provides expanded guidance on the capital assets scheme, including how to adjust input VAT when the use of capital assets changes, for example, when an asset moves from VATable to exempt activities.

What to do: Businesses with Bahrain operations should review their current invoice templates against the updated Section 10.3 requirements, and for any businesses holding capital assets that have changed use, review the updated input VAT adjustment methodology in Section 11.8.4.

What to Action This Month

Immediate (before 1 August 2026):
Review your VAT Group exit procedures if any entity has recently left or is leaving a VAT Group, the new directive applies from 1 August.

This quarter:

• Free zone businesses in distribution activities, begin organising documentation for the 
• AUP report requirement.
• Digital currency businesses, select your three approved exchange platforms and establish your conversion documentation process.
• Judicial expert services providers, assess whether VAT registration is required.
• Educational institutions, review your current VAT treatment against the new guide.
• Banks with AT1 instruments, confirm CT return treatment aligns with CTP012.

Before your next CT filing:
Review related-party transactions for potential downward TP adjustments under CTP011, and ensure full documentation is in place.

If you have KSA operations:
Check whether you fall within Wave 25 of ZATCA’s e-invoicing integration phase and begin system integration planning for the February 2027 deadline.

How Nishe Can Help

These updates cover VAT, Corporate Tax, free zone compliance, transfer pricing, and cross-border e-invoicing, across three GCC jurisdictions. If any of them raises questions about your business’s current position, we’re here to help.

No lengthy process before we’ve understood your situation. Just a practical conversation about where you are and what the update means for you.

Get in touch with the Nishe team

Here’s your breakdown.

UAE: Major Amendments to the Tax Procedures Law

This is the most significant update in this round, and it changes the mechanics of how refunds, audits, and voluntary disclosures work across UAE tax.

Refund claims now have a hard deadline

Under the amended Article 38, refund claims for tax credit balances must generally be submitted within five years from the end of the relevant tax period. Miss that window, and the refund entitlement is permanently lost, there’s no further recourse.

There are some specific exceptions. If a credit balance arises because of an FTA decision issued after the five-year period, or within the final 90 days of that period, you have one year from the date the credit arises to submit your claim. For other credits arising after the original deadline, the window is 90 days.

The FTA is now required to formally notify taxpayers whether a refund claim has been approved, partially approved, or rejected, adding a layer of certainty that wasn’t previously guaranteed.

The practical takeaway: if your business has unclaimed input tax credits or overpayments sitting from several years back, the clock is now explicit. Review your position rather than assuming there’s no urgency.

Audit windows can now extend well beyond five years

The standard limitation period for tax audits and assessments remains five years. But several triggers now extend that window under the amended Article 46:

Submitting a refund claim in the fifth year extends the FTA’s audit period by two additional years. Submitting a voluntary disclosure in the fifth year extends it by one year. Cases involving tax evasion or failure to register remain subject to a 15-year limitation period, unchanged, but worth restating given how serious that exposure is.

There’s also a transitional rule: refund claims relating to periods older than five years (measured from 1 January 2026) are now permitted, but subject to a two-year audit period.

The practical takeaway: the timing of when you submit a refund claim or voluntary disclosure now has real consequences for how long your business remains open to audit. This isn’t purely a compliance question anymore, it’s a timing strategy question.

Excess tax credits now expire

Under the amended Article 9(3), excess input tax and overpayments must be utilised within five years. Once that period lapses, the FTA can no longer offset these balances against future liabilities, meaning unused credits may be permanently forfeited.

The practical takeaway: if your business has been carrying forward unused input tax credits without actively reviewing them, this is the update that should prompt a review. A credit balance sitting unused isn’t neutral anymore, it has a shelf life.

Voluntary disclosures are no longer always mandatory

Under the amended Article 10(5), voluntary disclosures will now only be mandatory in situations specifically prescribed by the FTA. Other errors can be corrected directly through the relevant tax return, a meaningful simplification for businesses dealing with minor or routine corrections.

This reduces administrative burden, but it shifts more judgment onto businesses to determine which errors genuinely require a formal disclosure and which can be handled through normal return correction.

The FTA can now issue binding guiding decisions

A new Article 54(bis) empowers the FTA to issue binding interpretative decisions that apply to both the Authority and taxpayers. This is a meaningful shift toward greater consistency, once the FTA issues a binding decision on a point of interpretation, both sides are bound by it going forward.

A one-year transitional window is open right now

A one-year transitional period, starting 1 January 2026, allows taxpayers to submit refund claims that would otherwise have lapsed under the new five-year rule. These claims remain subject to the extended two-year audit period, but the door that would otherwise be closed is open for this transitional year.

The practical takeaway: if your business has historical refund positions that you assumed were no longer recoverable under the old rules, this transitional window is worth checking before it closes.

UAE: Cabinet Decision No. 129, FTA Registration Details Must Be Kept Current

Cabinet Decision No. 129 of 2025 is now practically implemented, reinforcing an obligation that’s easy to overlook: taxpayers must notify the FTA of any changes to their registration information within 20 business days of the change.

This covers trade licence renewal details, business activities, changes to shareholders, managers, or directors, and changes to business address and contact information.

The penalties are real: AED 1,000 for the first violation, and AED 5,000 for any repeat violation within 24 months.

This is a low-drama, high-frequency compliance risk, the kind of thing that doesn’t get attention until a penalty notice arrives. If your business has had a director change, a trade licence renewal, or an address change in the last few months, check whether the FTA has been notified within the required window.

UAE: New Guidance on Taxation of Family Foundations

The FTA has issued CTGFF1, a dedicated guide on how Corporate Tax applies to Family Foundations.

This guidance covers the requirements to qualify as a fiscally transparent Family Foundation, how the Corporate Tax Law treats Family Foundations specifically, how the law applies to beneficiaries, and the registration and compliance obligations that apply to both Foundations and their beneficiaries.

For UAE family-owned business groups operating through a Foundation structure, or considering one, this guidance is directly relevant. Fiscal transparency status has significant implications for how income flowing through the Foundation is taxed, and the qualifying conditions need to be met precisely.

The practical takeaway: if your business operates through a Family Foundation structure, or you’re considering one as part of succession or wealth structuring, this guide should be reviewed alongside your current arrangements to confirm continued qualification.

UAE: E-Invoicing ASP Deadline, Confirmed at 30 October 2026

For businesses with annual revenue of AED 50 million or more, the deadline to appoint an Accredited Service Provider under the UAE Electronic Invoicing System is confirmed at 30 October 2026, with mandatory implementation by 1 January 2027.

This has been covered in detail in our previous updates, the key point remains the same: appointing your ASP is the starting point, not the finish line. The data readiness, systems integration, and process redesign work needs to happen between appointment and go-live.

Bahrain: Comprehensive DMTT Transfer Pricing Guidance

Bahrain’s National Bureau for Revenue has issued detailed guidance on transfer pricing under the Domestic Minimum Top-up Tax framework, introduced under Decree-Law No. 11 of 2024 and effective from September 2024.

This guidance is aligned with OECD Transfer Pricing Guidelines and is directly relevant for multinational enterprise groups with Bahrain operations.

The arm’s length principle, applied properly

All transactions between related parties, Constituent Entities, Joint Ventures, and Subsidiaries within the same MNE Group, must reflect conditions that would exist between independent parties. The underlying objective is straightforward: profits should be taxed where economic value is genuinely created and where risk is genuinely assumed.

Compliance requires a thorough functional and comparability analysis, properly documented in both local and master files, not a retrospective justification built after the fact.

Comparability analysis, the four factors that matter

To apply the arm’s length principle correctly, entities need to identify the commercial and financial relationships at play, accurately delineate the controlled transaction, and compare it against similar transactions between independent parties.

The key comparability factors are contractual terms, the functions performed and assets and risks involved, the characteristics of the goods or services, the commercial and economic circumstances, and the business strategies involved.

Five approved transfer pricing methods

The guidance confirms five approved methods: Comparable Uncontrolled Price (CUP), Resale Price Method, Cost Plus Method, Transactional Net Margin Method, and Profit Split Method.

The most appropriate method should be selected based on the specific facts of the transaction and the data available, and where CUP is equally reliable as an alternative method, it’s the preferred choice.

Documentation, local file and master file

Two distinct documentation requirements apply. The local file covers detailed information on specific controlled transactions involving Bahrain entities, business activities, transaction details, comparability analysis, the transfer pricing method selected, and supporting financial data.

The master file provides a comprehensive overview of the MNE Group’s global operations, value drivers, supply chains, intangibles, financing arrangements, and consolidated financials.

Both files must be prepared and maintained as prescribed under the Executive Regulations, not produced reactively when requested.

The practical takeaway: if your business operates as part of an MNE group with Bahrain entities, your transfer pricing policy and documentation need to genuinely reflect how the business actually operates, not a policy document that sits separately from operational reality.

Bahrain: DMTT Computation Guide

A separate, detailed guide addresses how the Domestic Minimum Top-up Tax is actually calculated for MNE groups within scope, specifically those with annual consolidated revenues of at least EUR 750 million.

The computation starts with the financial accounting income or loss of Bahrain constituent entities, followed by prescribed adjustments to arrive at GloBE income and covered taxes.

IFRS is recognised as an acceptable accounting standard for this purpose. Entities using other authorised standards, including AAOIFI, may need to adjust for material differences from IFRS where these create what’s termed a Material Competitive Distortion.

The guide introduces a structured methodology for identifying and assessing material accounting differences, including quantitative materiality thresholds linked to the scale of the Bahrain operations within the broader multinational group. Detailed guidance is also provided on consolidated financial statements, fiscal year alignment, permanent establishments, flow-through entities, and currency conversion.

The practical takeaway: if your group falls within the EUR 750 million revenue threshold and has Bahrain operations, this computation methodology needs to be built into your DMTT compliance process, not treated as a one-off calculation exercise.

UAE: Pillar Two Registrations Now Live on EmaraTax

Constituent entities of in-scope MNE groups can now register for the Qualified Domestic Minimum Top-up Tax directly through the EmaraTax portal. If your group falls within Pillar Two scope, this registration step is now operational and should be actioned.

What to Do This Month, Action Checklist

UAE businesses:
Review historical refund claims and credit balances against the new five-year limitation period, and check the one-year transitional window if older claims may apply.
Confirm your FTA registration details are current, trade licence, business activities, directors, and address, within the 20 business day requirement.
If you operate through a Family Foundation structure, review the new CTGFF1 guidance against your current arrangements.
If your revenue is above AED 50 million, confirm your e-invoicing ASP appointment timeline against the 30 October deadline.
If your group is in-scope for Pillar Two, register for DMTT via EmaraTax.

Bahrain-linked businesses:
If part of an MNE group with Bahrain operations, review your transfer pricing documentation against the new local and master file requirements.
If your group meets the EUR 750 million threshold, ensure your DMTT computation methodology aligns with the new guidance.

How Nishe Can Help

These updates span tax procedures, FTA compliance, family wealth structuring, e-invoicing, and cross-border transfer pricing. If any of them raises questions about your specific position, we’re happy to talk.

Here’s your breakdown of everything that matters, with clear guidance on what to do next.

UAE: E-Invoicing ASP Deadline Confirmed for 30 October 2026

The Ministry of State for Financial Affairs has issued Ministerial Decision No. 66 of 2026, formally confirming the amended deadline for businesses to appoint an Accredited Service Provider under the UAE’s Electronic Invoicing System.

Who this affects: All entities with annual revenue of AED 50 million or more.

What the deadline is: 30 October 2026. This is the date by which qualifying businesses must formally appoint their ASP through the MRI tax portal.

What hasn’t changed: The mandatory go-live date remains 1 January 2027. Appointing an ASP by October is the prerequisite the implementation, data preparation, systems integration, testing, and workflow redesign all need to happen in the months between appointment and go-live.

The practical implication here is straightforward: the extension from July to October gives businesses more time to select the right provider. It does not compress the preparation work. If anything, businesses that use the extension wisely, choosing their ASP carefully, assessing their data gaps thoroughly, and building a proper implementation programme, will be the ones that go live without disruption.

If you haven’t started your e-invoicing readiness assessment, the time to do it is now or speak to one of the team at Nishe

UAE: Corporate Tax Deadline Reminder — 30 June 2026

For UAE businesses with a financial year end in September, the Corporate Tax filing deadline falls on 30 June 2026.

If your business falls into this category, your CT return must be submitted within 9 months of your financial year end. For September year-end businesses, that means the deadline is this month.

If you haven’t started your CT return preparation or if you have outstanding questions about your taxable income calculation, related party transactions, or deductibility positions this is urgent.

The FTA is actively enforcing compliance and cross-referencing data across filings. Common areas that flag on CT returns include related party transactions without arm’s-length documentation, entertainment expenses claimed at 100% rather than the permitted 50%, and owner salary versus dividend structures that haven’t been reviewed against CT deductibility rules.

What to do: If your CT filing deadline is 30 June, contact your finance team or advisor today. Don’t leave this to the final week.

Saudi Arabia: Real Estate Transaction Tax, Comprehensive New Guidance Issued

ZATCA has released Version 6 of its Detailed Real Estate Transaction Tax Guideline. Its most comprehensive interpretation of the RETT Law introduced in April 2025. The guideline doesn’t change the law, but it clarifies in significant detail how ZATCA will apply it in practice.

This matters for real estate investors, developers, family-owned groups with property holdings, and businesses involved in Islamic finance transactions.

The key clarifications:

Indirect transfers of real estate companies are now clearly addressed. RETT applies when ownership reaches 30% or more and the transfer itself is 30% or more. A 3-year lookback rule means that smaller transactions can be aggregated, so a series of smaller transfers that individually fall below the threshold may collectively trigger RETT liability.

Capital increases are generally not taxable where ownership percentages remain unchanged. Where new investors are involved, pre-increase interests must typically be retained for 5 years to preserve the exemption. This is an important planning consideration for businesses bringing in new shareholders.

Islamic finance transactions receive important clarification: RETT is charged only once, on the initial transfer in Murabaha and finance lease structures. The transfer of title back to the customer at the end of the arrangement is not taxed again. This removes a significant uncertainty for Islamic finance transactions.

Valuation for BOOT projects is now confirmed to be based on Fair Market Value at the actual transfer date, not the contract signing date, which can differ significantly in long-term infrastructure projects.

More than 26 exemption categories are recognised, including family gifts, Waqf transfers, debt settlements, spousal transfers, government expropriations, and specific off-plan transactions. If you have a real estate transaction under consideration, checking the exemption list is a worthwhile first step.

What to do: If your business has KSA real estate holdings, is involved in property development or investment, or has indirect exposure through a corporate structure, review your position against the new RETT guidance. The 3-year lookback rule on indirect transfers means historical transactions may have ongoing implications.

Qatar: New Tiered Excise Tax on Sweetened Drinks, Effective 6 July 2026

Qatar’s General Tax Authority has issued guidance on a new Tiered Volumetric Excise Tax Model for sweetened drinks, effective 6 July 2026.

This is a material change for any business involved in the manufacture, import, or distribution of sweetened beverages in Qatar.

What’s changing: Tax rates will now vary based on the total sugar content of the beverage a tiered model replacing the previous flat-rate approach. Carbonated drinks are now brought within the broader sweetened drinks framework.

What’s in scope: Ready-to-drink beverages, concentrates, powders, and similar drink products containing added sugar or sweeteners.

What’s out of scope: Qualifying natural juices, specified dairy products, infant formula, and medical nutrition products.

The practical challenge: Product registration under the new regime requires supporting nutritional and laboratory documentation. This is not a quick administrative exercise — businesses need to assess their product classifications and ensure the documentation is in place before the effective date.

Transitional rules may apply to businesses holding a significant stock of sweetened drinks before 6 July. Reviewing your inventory position now could avoid an unintended tax liability on existing stock.

What to do: If your business manufactures, imports, or distributes sweetened beverages in Qatar, start your product classification review immediately. 6 July is close.

Bahrain: Tax Agent and VAT Representative Rules Updated

Bahrain’s National Bureau for Revenue has released Version 2.0 of its Tax Agent and VAT Representative Guide, updating the rules for taxpayer representation in relation to VAT and the Domestic Minimum Top-Up Tax.

The key practical updates:

Tax agents may now represent both resident and non-resident taxpayers for VAT and DMTT matters, including filings, inquiries, and appeals. This expands the scope of what a tax agent can do on a client’s behalf.

VAT representatives remain restricted to representing non-resident VAT registrants only. Importantly, VAT representatives are jointly liable for VAT obligations and penalties, meaning the representative takes on real financial exposure for the client’s compliance.

Authorisation is valid for three years, with a BHD 300 approval and renewal fee.

The inclusion of DMTT within the scope of tax agent services reflects Bahrain’s continued implementation of its Pillar Two framework. For multinational groups with Bahrain entities, ensuring your tax representation arrangements are current and cover DMTT is worth checking.

What to do: If you operate through a tax agent or VAT representative in Bahrain, verify that their authorization is current and that their scope of representation covers DMTT where relevant.

Saudi Arabia: KSA VAT Refund Deadline for Non-Resident Businesses — 30 June 2026

If your business is registered outside Saudi Arabia and incurred VAT on qualifying business expenses in KSA during 2025 you have until 30 June 2026 to claim a refund.

This is a relatively narrow window, and the requirements are specific:

Your business must have no establishment or VAT registration in Saudi Arabia. You must generally be VAT registered in your home jurisdiction. The reciprocity requirement must be satisfied, meaning Saudi Arabia must recognise refund eligibility for businesses from your jurisdiction. VAT on entertainment, non-business expenses, and other restricted items is not recoverable.

Applications must be supported by valid tax invoices, proof of payment, and supporting documentation. Given the documentary requirements, if you believe you may be eligible, start the review process now rather than attempting to pull everything together in the final days before the deadline.

What to do: If your business had KSA business expenses in 2025 and you’re not Saudi-registered, assess your eligibility and get your documentation together before 30 June.

Your Action List For This Month

Urgent (before 30 June): UAE September year-end businesses: file your CT return Non-resident businesses with 2025 KSA expenses, submit your VAT refund claim to ZATCA

Immediate (this week): Qatar sweetened drink businesses, start product classification review ahead of 6 July Bahrain tax agent/VAT representative, verify authorization covers DMTT

Before October: UAE businesses above AED 50M revenue, appoint your ASP by 30 October Begin or accelerate your e-invoicing readiness assessment, go-live is January 2027

Before December: Historical UAE VAT refund window, review 2018-2021 VAT positions before 31 December 2026 IFRS 18 gap assessment, capture 2026 comparative data in a restateable format

How Nishe Can Help

These updates span Corporate Tax, e-invoicing, VAT, real estate tax, and excise — across four GCC jurisdictions. If any of them raises questions about your current position, we’re happy to talk.

No lengthy process before we’ve understood your situation. Just a practical conversation about where you are and what you need.

Get in touch with the Nishe team

The Federal Tax Authority has been busy. Three significant updates have landed in the past few weeks, covering VAT refunds for UAE nationals, Corporate Tax accountability, and a new self-assessment tool that every business should know about. There’s also a notable development from Saudi Arabia that matters for any business with GCC operations.

None of these is headlines for the sake of headlines. Each one has practical implications for how your business operates, who is accountable for what, and in some cases, whether money you’re entitled to is sitting unclaimed.

Here’s what you need to know.

1. VAT Refunds for UAE Nationals Building New Homes, Are You Leaving Money on the Table?

If you’re a UAE national who has recently built or is currently building a new private residence, there is a formal VAT refund mechanism available to you, which covers more than most people realise.

What’s eligible for a refund

The refund applies to VAT paid on building materials such as; bricks, tiles, built-in kitchen units, central air conditioning, doors, and sanitary units, as well as VAT on contractor services, including builders, architects, and engineers.

What’s not eligible is equally important to understand: furniture, appliances, landscaping, swimming pools, and any removable items fall outside the scope of the refund. The boundary is essentially between what’s built into the structure and what’s brought in afterwards.

How to apply

Applications are submitted through the FTA’s Maskan app or the EmaraTax platform. You’ll need your Emirates ID, Family Data (the digital alternative to the Family Book), a property completion certificate, a site plan, proof of land ownership, and a bank letter with your IBAN.

Two points on the bank letter worth flagging: this must be an official letter from your bank and not a screenshot, not a statement. This is one of the most common reasons applications get delayed or rejected, and it’s entirely avoidable.

The deadline you can’t miss

You have 12 months from residence completion to apply, where completion is defined as the earliest of occupancy, the completion certificate, or an FTA-stipulated date. For retention payments made to contractors, a second claim can be submitted within 6 months of that payment.

Once a complete application is submitted, the FTA processes refunds within 20 business days..

2. Corporate Tax: Who Is Actually Accountable? The FTA Has Now Clarified This.

This one matters for every UAE business operating under the Corporate Tax regime and particularly for businesses where governance structures don’t perfectly match operational realities.

The FTA has issued guidance under CTP010 clarifying exactly what “director” and “officer” mean for Corporate Tax compliance purposes.

The definitions in plain English

A director is any individual formally appointed to the board of a juridical person, executive and non-executive, whether or not they’re involved in day-to-day management. If you’re on the board, you’re a director for CT purposes.The FTA indicated that individuals acting in a director-like capacity may also fall within the definition even without a formal title or appointment.

An officer is broader. It covers any individual holding a senior managerial or decision-making role, general managers, CEOs, CFOs, or anyone exercising significant control over business operations. The critical point: it doesn’t matter what your title says. What matters is what you actually do.

The substance over title principle

The FTA has been explicit that this is a substance-over-form assessment. If someone is making material business decisions, controlling operations, or exercising governance authority, they are an officer for Corporate Tax purposes, regardless of how their role is formally designated.

This has three immediate implications:

• Tax compliance accountability cannot be delegated away through nominal titles or restructured roles. If you have the authority, you have the responsibility.
• Businesses that have structured their governance to create separation between decision-making authority and formal accountability need to review that structure now, not when an FTA inquiry arrives.
• This aligns UAE Corporate Tax with international governance and substance principles, signalling that the FTA is approaching compliance with increasing sophistication.

What to do now

Review your current governance structure and map it against this guidance. Are all individuals who exercise material control formally identified in your Corporate Tax framework? If there are gaps between formal designation and actual authority, those gaps need to be closed.

3. The FTA’s New Tax Registration Self-Assessment Tool is Useful, But Not a Substitute for Advice

The FTA has launched a Tax Registration Self-Assessment Tool on the EmaraTax platform and it’s a genuinely useful starting point for businesses that are uncertain about their registration obligations.

How it works

The tool asks four questions: whether the applicant is a company or individual, whether the entity is incorporated in the UAE, whether taxable revenue exceeds or is expected to exceed AED 375,000, and whether the business is involved in excise goods such as tobacco, e-cigarettes, or sweetened beverages.

Based on the answers, it returns one of three outcomes: likely required to register, unlikely required to register, or seek professional advice.

The important caveat

This is a screening tool, not a definitive assessment. For straightforward cases, it provides a useful and quick indication. For anything with complexity, businesses operating across free zones and mainland, entities with mixed taxable and exempt supplies, or businesses with related party arrangements, the tool’s output is a starting point, not a conclusion.

The “seek professional advice” outcome is worth taking at face value. In our experience, the situations where businesses most need a detailed assessment are often the ones where initial assumptions suggested registration wasn’t required.

The practical value

For finance leaders onboarding new entities, subsidiaries, or JV structures, running them through this tool as an early checkpoint is a reasonable part of the process. It won’t replace a proper analysis, but it will flag obvious registration requirements quickly.

The tool is available at tax.gov.ae.

KSA Update: ZATCA Issues Guidance on Zakat Returns Relevant for GCC Operations

For businesses with Saudi Arabian operations, ZATCA issued a Guidance Manual in April 2026 clarifying how zakat return items should be treated.

The practical points are significant:

• The filing deadline is confirmed at 120 days. The reassessment period has been extended to 10 years for late filings, a meaningful increase in exposure for businesses that have historically been less than precise about their zakat positions.
• Record retention is now required for 10 years, with the burden of proof sitting firmly with taxpayers. The calculation of the zakat base, combining equity, liabilities, and adjusted profits, has been clarified, with the introduction of minimum and maximum zakat base concepts.
• ZATCA’s audit powers have also been expanded under this guidance.

The guidance applies to fiscal years starting on or after 1 January 2024. If you have Saudi entities and your zakat compliance hasn’t been reviewed recently, this is a reasonable trigger to do so.

What to Do Now

• If you’re a UAE national who has recently built a new home: check your eligibility for a VAT refund and apply within your 12-month window. Don’t let the deadline pass.

• If you have a UAE business under Corporate Tax: review your governance structure against the new director and officer definitions. Ensure that everyone exercising material authority is appropriately identified in your CT framework.

• If you have new entities, subsidiaries, or JVs: run them through the FTA’s self-assessment tool as a first check, then follow up with a proper analysis for anything complex.

• If you have Saudi operations: review your zakat return positions, record-keeping, and filing history against the new ZATCA guidance. The 10-year reassessment window means historical positions matter.

How Nishe Can Help

These updates touch Corporate Tax governance, VAT compliance, and GCC regulatory management, all areas where our team works every day.

If any of the above has raised questions about your current position, or if you’d like a second opinion on your governance structure, compliance framework, or cross-border tax position, we’re happy to talk.

No lengthy process before we understand your situation. Just a practical conversation about where you are and what you need.

Get in touch with the Nishe team

Three significant updates have landed in the UAE tax framework in 2026. If you’re a CFO, Finance Director, or senior finance leader, these aren’t distant regulatory footnotes — they have direct implications for your compliance calendar, your cash position, and how you structure your finance function.

Here’s what you need to know

Update 1: UAE R&D Tax Credit — A Real Incentive for Innovation-Led Businesses

What’s changed

The UAE Cabinet has introduced a formal R&D Tax Credit framework under Cabinet Decision No. 215 of 2025, effective 1 January 2026. Ministerial Decision No. 24 of 2026 has since provided the implementation details.

For the first time, UAE businesses conducting qualifying research and development activities can offset their Corporate Tax liability, at rates that scale with the size of their R&D investment.

The credit rates:

• 15% credit on the first AED 1 million in qualifying R&D spend (minimum 2 R&D staff)
• 35% credit on spend between AED 1–2 million (minimum 6 R&D staff)
• 50% credit on spend between AED 2–5 million (minimum 14 R&D staff)

Minimum qualifying expenditure per project: AED 500,000.

What counts as qualifying expenditure?

Staff costs (uplifted by 30% for overheads), consumables, subcontracting fees, and contributions under cost-sharing arrangements. Activities must be novel, systematic, and conducted within the UAE; social sciences, humanities, and arts are excluded.

What it means for your business

If your business invests meaningfully in product development, technology, or process innovation, this framework could reduce your Corporate Tax liability significantly. Credits can be carried forward if unused and transferred between entities with at least 75% common ownership.

The catch: pre-approval from the Emirates Research and Development Council is required before you can claim. You’ll also need audited financials, a detailed expenditure breakdown, and seven years of technical documentation.

What to do next

Review your current R&D activities against the qualifying criteria. If you think you may be eligible, begin the pre-approval process with the Council now — this isn’t something you can retrospectively claim without the right documentation in place.

Update 2: FTA Decision No. 5 — Clarifications, Directives, and How to Get Certainty on Your Tax Position

What’s changed

The FTA has issued Decision No. 5, which formalises the framework for how it issues clarifications, directives, and administrative decisions. For businesses navigating complex tax positions, particularly in transfer pricing, VAT recovery, and related-party transactions, this is important operational knowledge.

Key points:

Private clarifications are now formally binding on the FTA where the facts match but they apply only to the specific taxpayer who requested them. They won’t be issued if you’re already under audit or if the matter involves potential tax avoidance.

Advance Pricing Agreements (APAs) are available for related-party transactions with a minimum value of AED 100 million, covering 3–5 years. Currently, only unilateral APAs are permitted.

Input tax apportionment if the standard VAT recovery method produces an unfair result for your business, you can now formally request an alternative method. If approved, you must use it for 2–4 years.

Administrative exceptions on tax invoices, credit notes, and export evidence are available and valid for up to 3 years.

What it means for your business

If you’ve been operating in grey areas, particularly on VAT recovery, intercompany transactions, or export treatment, this framework gives you a legitimate route to get certainty. A private clarification, once issued, is binding on the FTA. That’s meaningful protection.

What to do next

If you have unresolved tax positions, uncertain VAT recovery calculations, or significant related-party transactions, consider whether a formal clarification or APA makes sense. The process requires complete, accurate information; an incomplete application will be closed.

Update 3: Tax Procedures — The 2026 Updates Every Finance Team Needs to Act On

What’s changed

Amendments to the UAE Tax Procedures framework (Cabinet Decision No. 74 of 2023 and related 2026 updates) have introduced changes that affect compliance timelines, voluntary disclosure obligations, and refund windows. These are live now.

The five changes that matter most:

1. Five-year limitation period, now formally reinforced Tax assessments, voluntary disclosures, and refund claims are all subject to a clear 5-year statute of limitations. If something is wrong in your historical tax position, the window to correct it is not indefinite.
2. Voluntary disclosure threshold is now relaxed Not every error now requires a voluntary disclosure. The focus has shifted to material errors that affect payable tax. This reduces the compliance burden but increases the importance of documented judgment calls.
3. Historical VAT refund window will close on 31 December 2026 Businesses can claim refunds for VAT periods dating back to 2018–2020, but only until the end of this year. This is a one-time opportunity that will not be extended.
4. Stricter audit readiness expected FTA audits are becoming more data-driven. The expectation for supporting documentation, evidence-based tax positions, and audit trails has increased materially.
5. 20 business day update window Changes to tax records must now be filed within 20 business days. Periodic reviews are no longer sufficient and your compliance processes need to be close to real-time.

What it means for your business

The historical VAT refund window is the most time-sensitive item here. If your business has been operating since 2018 and hasn’t reviewed early VAT positions, this is worth doing before December 2026. The potential recovery could be material.

What to do next

Run a rapid review of your VAT positions from 2018–2020. Assess whether any errors in your current tax records require voluntary disclosure. And make sure your documentation standards are audit-ready — not just compliant on paper.

How Nishe Can Help

These updates touch three areas where we work every day: Corporate Tax compliance and planning, VAT and tax procedure management, and finance function readiness.

If any of the above has raised questions about your current position, or if you’re not sure whether your business qualifies for the R&D Tax Credit, we’re happy to have a straightforward conversation.

No jargon. No lengthy engagement letters before we’ve even spoken. Just clarity.

Get in touch with the Nishe team

Or take our free UAE E-Invoicing Readiness Scorecard while you’re here 

The opportunity (and the risk) is the same: the teams who translate these updates into practical actions will stay calm and in control. The ones who treat them as “something for later” will feel it operationally—at month-end, during audits, and when deadlines land.

Here are four updates worth having on your radar—and the simplest next steps we recommend.

1) UAE e-Invoicing Guidelines (v1.0): scope is clearer, readiness matters

The Ministry of Finance released the UAE Electronic Invoicing Guidelines (Version 1.0) on 23 February 2026.
For CFOs, the most useful part is that it frames e-invoicing as an ecosystem with defined transaction types in scope and clear roles and responsibilities across stakeholders.

One detail that helps planning: the guidance outlines transaction scope by supplier/buyer type (e.g., B2B, B2G, etc.).

What to do next:

• Treat this as a readiness programme, not an IT ticket. Assign finance-led ownership and a cross-functional working group. 
• Map your invoice journey end-to-end (issue → approvals → send → rejections/credit notes → audit trail). 
• Start with data quality: consistent customer/supplier master data and structured invoice fields will save you later. 
• Clarify responsibility boundaries with your provider/ASP early (especially around errors, rejections and resolution). 

2) Excise Tax (ETGTP2): updated guidance on excise goods + calculations

The FTA’s Taxable Persons Guide (Excise Goods) — Excise Tax | ETGTP2 (February 2026) provides an overview of excise goods, including definitions/exclusions and how to calculate Excise Tax under both the Ad Valorem Model and Tiered-Volumetric Model.

It’s particularly relevant if your business imports, produces, stockpiles excise goods, or manages operations tied to designated zones/warehousing.

The guide also references administrative requirements connected to the Tiered-Volumetric model—such as obtaining certification relating to sugar content (where applicable).

What to do next:

• Confirm whether any of your product lines fall within excise categories and whether your current classification is still appropriate. 
• Pressure-test your excise calculation approach (model, valuation method, documentation). 
• If sweetened drinks are in scope for you, review the operational requirements around content verification and supporting evidence. 

3) Corporate Tax: new exemption route for certain sports entities

The Ministry of Finance issued Cabinet Decision No. 1 of 2026 relating to exempting certain sports entities from Corporate Tax under the Corporate Tax framework.

For qualifying entities, the key practical point is that exemption is conditional: entities may need to provide information to verify eligibility, and failing to meet conditions can result in losing exemption status for the relevant tax period.

What to do next:

• If you’re a sports entity (or connected/ancillary organisation), don’t assume exemption automatically applies—document eligibility and governance clearly. 
• Maintain discipline on “unrelated commercial activity” risk: exemptions often fail at the edges. 
• Prepare supporting documentation that could be requested to verify eligibility. 

4) EmaraTax process: Corporate Tax registration/resubmission via Tasheel Agent + UAE PASS

The FTA’s EmaraTax user manual outlines the process for Corporate Tax Registration and Re-Submission by a Tasheel Agent to assist the taxpayer via UAE PASS.

In plain terms: it’s a structured way for a Tasheel Agent to support registration steps while using UAE PASS authentication flows (including OTP and app-based confirmation).

What to do next:

• If your registration journey has complexity (group structures, multiple owners, documentation gaps), consider whether agent-assisted submission reduces friction. 
• Ensure internal readiness: UAE PASS access, updated contact details, and a clear document pack before starting the submission flow. 
• If you’re resubmitting after an “Awaiting Information” status, treat it like a mini project: gather evidence, align internally, then respond clearly. 

The bigger picture for CFOs

These aren’t random updates. They point to a clear direction: more digitisation, more structured data, clearer accountability, and tighter evidence trails.

The finance teams that will thrive are the ones who:

• keep compliance simple (but not simplistic), 
• build reliable processes, 
• and turn change into operational strength rather than last-minute stress. 

How Nishe can help

If you’d like support making this practical, we can help in three ways:

1. E-invoicing readiness review (process + data + controls + stakeholder roles) 
2. Tax guidance translation (Excise / CT updates → real actions and documentation) 
3. EmaraTax registration support (document pack + submission clarity + resubmission preparation) 

If you want to sanity-check your readiness, reach out to our team—happy to point you in the right direction.