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.

While some changes focus on process improvements inside EmaraTax, others introduce new guidance that could affect VAT reporting, excise compliance, and corporate tax planning.

Here’s a clear breakdown of what’s changed and what it means for your business.

UAE Updates

1. Reactivating Deactivated Corporate Tax TRNs, Process Now Formalised

The FTA has released an official user manual explaining how businesses can reactivate a deactivated Corporate Tax TRN through EmaraTax.

This includes:

• Viewing deactivated TRNs
• Selecting “Reactivate TRN”
• Completing and submitting the reactivation request

The update removes uncertainty around the process and confirms it is now fully supported within the portal, not a workaround.

Why it matters:
Businesses restarting operations or becoming taxable again can now reactivate registrations more efficiently, but must ensure data accuracy before submission.

2. New Advance Corporate Tax Payment Option

A new optional feature allows taxpayers to make advance corporate tax payments before filing their return.

Key points:

• Completely voluntary
• Does not change filing deadlines
• Payments sit as credit and offset future liabilities

Why it matters:
This gives finance teams greater flexibility for cash-flow planning and reduces last-minute pressure before the filing deadline.

3. VAT Profit Margin Scheme — New Guide Released (VATGPM1)

The FTA has clarified how eligible resellers can apply VAT only on profit margins rather than full selling value.

Applicable to:

• Second-hand goods
• Antiques
• Collectors’ items
• Goods with restricted input VAT recovery

Key reminders:

• The scheme is optional
• No FTA approval required
• Specific invoicing and record-keeping rules apply

Why it matters:
Businesses in resale sectors may reduce VAT exposure — but only if applied correctly.

4. Updated Excise Tax Guide for Taxable Persons

The new excise guide reinforces compliance expectations for businesses dealing with tobacco, energy drinks, sweetened beverages and vaping products.

Highlights include:

• No minimum turnover threshold for registration
• Tax due upon import, production or release
• Tiered sugar-based taxation rules

Why it matters:
Excise compliance is tightening, and businesses must ensure timely registration, reporting and record-keeping.

Bahrain Updates

VAT Real Estate Guide — Lease Incentives Clarified

The updated guide confirms that lease incentives (rent-free periods, fit-out contributions, etc.) must be included when calculating VAT.

Why it matters:
Both landlords and tenants need to review agreements to ensure VAT reflects the full economic value of leases.

VAT Treatment of Manpower Services

New guidance clarifies VAT treatment for outsourced labour and staffing services.

Why it matters:
Businesses using recruitment agencies or contract staff should review invoices to ensure correct VAT treatment.

Final Thoughts

Across the GCC, tax systems are becoming more structured, digital and data-driven.

The trend is clear:

• clearer processes
• stronger compliance expectations
• more transparency in reporting

Businesses that stay informed and act early will avoid unnecessary risk and disruption.

At Nishe, we help organisations translate regulatory updates into practical action, from tax planning to system implementation.

This transition will not look the same for every organisation. A fast-growing SME will not have the same needs as a multinational group running complex ERP environments. That’s why this guide breaks down two clear pathways:

Most firms focus only on the 50 mandatory fields required for compliance

Conditional Mandatory (CM) and Optional fields are often ignored. E-invoicing standards include 200+ data fields in total

CM and Optional fields carry critical business, tax, and reconciliation value

Ignoring them leads to poor data quality, manual reconciliations, and limited automation. We handle all 200+ fields, not just the mandatory ones

Ensures: true compliance, better analytics & reporting, end-to-end automation readiness

We also explore data and process gap assessments, integration tips, training considerations, vendor selection, and realistic timelines — so UAE businesses can prepare with confidence, not pressure.

Why E-Invoicing Implementation Matters Now

E-invoicing isn’t just another regulatory box to tick. It represents a shift in how transactions are issued, exchanged, stored, and validated. Once implemented, invoices will move through an approved Accredited Service Provider (ASP) — using a structured digital format based on Peppol standards.

Success will depend on early decision-making:
➡️ Choosing the right solution
➡️ Preparing data
➡️ Training teams
➡️ Aligning systems and processes

Starting now gives businesses time to solve issues before invoices become non-compliant — and penalties apply.

Implementation Pathway for SMEs: Simple, Fast, and Cost-Effective

For SMEs, e-invoicing does not need to be a heavy IT project. Most will be able to comply through plug-and-play cloud portals or accounting software plugins.

Step 1 — Assessment Process
We’ll look at where you’ve got gaps in your data, and where we might have to do to fix those

Step 2 — Select an Accredited Service Provider (ASP)
Once the ASP list is published, SMEs should focus on:

• Ease of use
  
• Cloud access
  
• XML conversion automation
  
• Error detection and alerts
  
• Simple onboarding

Step 3 — Issue Invoices Through the ASP Portal
Instead of building custom integrations, SMEs can:

• Create invoices directly in the ASP system

• Upload invoices generated elsewhere

• Rely on automated transmission to the FTA network

Step 4 — Train A Finance Owner
A single team member should monitor invoice status, rejections, and archiving.

Pro tip: Many ASPs are planning free invoice allowances for smaller businesses — making implementation low-cost and low-risk.

Implementation Pathway for Large Enterprises: A Structured Integration Project

For large organisations, e-invoicing implementation is closer to a finance-and-technology transformation programme. ERP integration alone may take 6–12 months, depending on system complexity.

Phase 1 — Assessment
Identify invoicing workflows, data gaps, VAT mappings, credit note handling, process gaps, people gaps and XML field availability.

Phase 2 — Solution Selection
Evaluate ASPs based on:

• Peppol experience
  
• Connector availability
  
• Data security
  
• Scalability
  
• Local Support capability

Phase 3 — Integration
Typical architecture options:

• Direct API integration
  
• Middleware connectors
  
• Hybrid cloud models

Master data accuracy will decide success.

Phase 4 — Testing
Run parallel scenarios:

• Invoice creation
  
• Validation
  
• Rejection handling
  
• Credit notes
  
• Amendments

Phase 5 — Go-Live
Implement by business unit or region before scaling.

Timeline guidance: Projects should begin in 2025 to allow safe margin for error.

How to Choose the Right ASP

Once the accreditation register is published, businesses will need to review:

• Approved provider status
  
• Connectivity with existing systems
  
• Cost-to-volume fit
  
• Training and onboarding
  
• Peppol experience
  
• UAE-specific support

This will be one of the most important decisions in the process.

Integration Tips for SAP, Oracle, Dynamics and Others

SAP users can use the native eDocument framework for XML creation and processing.

Oracle / NetSuite systems typically rely on middleware or third-party API connectors.

Dynamics / Zoho / SME platforms are likely to integrate through ASP plug-ins or cloud connectors.

Across all systems, three points matter most:
1️⃣ TRNs and VAT codes must be accurate
2️⃣ Credit note workflows must be mapped
3️⃣ Testing must start early

Training: The Most Overlooked Success Factor

Even the most advanced integrations will fail if people are not trained.
Teams need clarity on:
✔ How to generate invoices
✔ How to track status codes
✔ How to resolve rejections
✔ How to handle credit notes
✔ How to archive digital records

Key Takeaways

Start early — 2025 is the preparation year
Choose the pathway that fits your organisation
ASP selection will determine long-term success
Don’t underestimate ERP integration timelines
Train people before go-live, not after
E-invoicing is a strategic shift, not a formality

How Nishe Supports Businesses Through E-Invoicing

At Nishe, we work with organisations across the UAE and wider GCC to:

• Review system readiness
  
• Assess compliance gaps
  
• Support ASP selection
  
• Guide ERP integration
  
• Train finance teams
  
• Prepare data structures for your AP and AR workflows
  
• Manage testing and go-live

Whether you are a five-person SME or a multinational group, we can tailor support to match your scale and internal capabilities.

If your business is preparing — or unsure how to begin — our team is here to help.

Here’s a practical breakdown of the latest updates — and what they mean for businesses in real terms.

UAE Updates

1. FTA Decision No. 9 of 2025 – Refunds Can Be Declined During Audits

Effective: 1 January 2026

Under this decision, the FTA may withhold or decline VAT refunds where a taxpayer is under audit and certain risk conditions exist.

Refunds may be declined if:

• Significant tax risk is identified during the audit
• There are reasonable grounds to suspect tax evasion
• The refund relates to transactions linked to suspected evasion
• The taxpayer has overdue or outstanding tax returns 

Why this matters:
Refunds can no longer be treated as automatic. Businesses with weak documentation, unresolved filings, or audit exposure may face cash flow delays, even where a refund would otherwise be due.

2. FTA Decision No. 10 of 2025 – Sugar & Sweetener Calculation for Excise Tax

Effective: 1 January 2026

This decision introduces a clear mechanism for calculating sugar and sweetener content in concentrates, powders, gels, and extracts where no reliable guidelines exist.

Key points:

• Sugar content must be calculated based on the final prepared beverage
• Manufacturer instructions or an FTA-approved methodology must be used
• Supports accurate classification under the tiered sugar-based excise regime 

Why this matters:
This reduces ambiguity, strengthens consistency, and lowers the risk of disputes — but it also raises the bar for data accuracy and product classification.

3. FTA Decision No. 11 of 2025 – Additional Excise Tax Deduction Cases

Effective: 1 January 2026

This decision expands scenarios where previously paid excise tax may be deducted, while introducing tighter controls and documentation requirements.

Why this matters:
There are now clearer recovery opportunities — but only for businesses with robust records, traceability, and compliance processes.

4. VAT Administrative Exceptions Guide (VATGEX1)

The updated guide explains when the FTA may grant administrative relief from standard VAT obligations, such as:

• Registration or deregistration
• Filing deadlines
• Payment timelines
• Record-keeping requirements 

Exceptions are discretionary and must be formally requested with supporting evidence.

Why this matters:
This provides flexibility for genuinely exceptional cases — but it is not a workaround for poor compliance or late action.

5. Advance Pricing Agreements (APAs) – Corporate Tax Guide CTGAPA1

The new APA guide explains how businesses can agree transfer pricing methodologies in advance with the FTA.

Key benefits:

• Certainty on related-party pricing
• Reduced audit and adjustment risk
• Lower exposure to penalties 

Why this matters:
For groups with cross-border or related-party transactions, APAs are becoming a strategic risk-management tool, not just a technical option.

Bahrain Updates

1. Domestic Minimum Top-Up Tax (DMTT) Guide v1.2

Bahrain continues alignment with the OECD Pillar Two framework, introducing a 15% effective minimum tax for large multinational groups.

The updated guide clarifies:

• Scope and qualifying entities
• Registration responsibilities
• Safe harbours and transitional relief

2. VAT Deregistration Manual v2.0

The revised manual provides clearer guidance on:

• Voluntary vs mandatory deregistration
• Required documentation
• Procedural steps and timelines 

Why this matters:
Exiting VAT incorrectly can trigger penalties — this update reduces errors but increases expectations of accuracy.

Final Thoughts

Across the GCC, tax systems are becoming more precise, more digital, and more enforceable. Flexibility still exists — but only for businesses that act early, document properly, and engage proactively.

At Nishe, we help businesses interpret these updates, assess risk, and implement practical compliance strategies — without unnecessary disruption.

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

UAE UPDATES

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

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

This applies when a business:

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

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

FTA Guide

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

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

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

The updated framework modernises the penalty system by:

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

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

Cabinet Decision (Consolidated Penalties)
 

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

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

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

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

Excise Law Updates

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

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

Key penalties include:

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

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

E-Invoicing Penalties

BAHRAIN UPDATE

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

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

Key takeaways:

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

Bahrain Real Estate VAT Guide

Final Thoughts

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

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

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

At Nishe, we’ve summarised the most important updates your business needs to know this month — and what they mean in practice.

UAE: Dubai Opens Mainland Market Access for Free-Zone Companies

Resolution: Executive Council Resolution No. 11 of 2025

Dubai has introduced a landmark reform allowing free-zone companies to conduct business on the mainland — a move that could reshape corporate structures and market strategies.

Key Highlights:

• Free-zone entities can now operate outside their zones, provided they obtain the relevant licence or permit from the Dubai Department of Economy and Tourism (DET). 
• The rule excludes financial institutions licensed in the DIFC. 
• Companies must maintain separate financial records for mainland and free-zone activities. 
• DET and free-zone authorities will soon publish a list of eligible activities. 
• Existing entities have one year (extendable by another year) to regularise their operations. 

Why it matters:
This reform bridges the long-standing divide between mainland and free-zone business activities, allowing companies to scale more flexibly and operate with fewer structural barriers. However, compliance — particularly around accounting segregation — will be critical.

Oman: E-Invoicing Goes Live from August 2026

Oman joins the UAE and Saudi Arabia in adopting mandatory e-invoicing, marking another step toward digital tax administration across the GCC.

Implementation Timeline:

1. Publication of technical specifications (Nov 2025) – OTA to release XML/PEPPOL data standards
2. Accreditation of ASPs (Dec 2025 – Feb 2026) – Registration and testing for authorised providers
3. Go-Live Phase 1 (Aug 2026) – Top ~100 taxpayers mandated to issue e-invoices
4. Wider rollout (2027) – Onboarding by industry and turnover
5. Full implementation (By Aug 2028) – All B2B and G2B transactions covered

Key Features:

• Based on the PEPPOL 5-corner model (no pre-clearance). 
• Enables real-time invoice exchange between buyers and sellers. 
• Fully integrated with ERP/accounting systems. 
• Mandates secure digital archiving and audit trail functionality. 

Why it matters:
Oman’s e-invoicing system will transform financial reporting for taxpayers, particularly for large and mid-sized companies. Early preparation is essential to align systems, select an accredited service provider, and ensure compliance by the 2026 deadline.

Qatar: New Requirement for Withholding Tax (WHT) Returns

Taxpayers in Qatar filing WHT returns via Dhareeba must now include a Contract Declaration Reference Number before submission.

Key Takeaways:

• If the related contract has not been declared, WHT submission cannot proceed. 
• The contract reference number must appear in the “Transactions” section in Dhareeba. 
• Businesses should declare contracts early to avoid delays. 

Why it matters:
This change strengthens the link between contract declarations and WHT payments, reinforcing transparency in corporate tax compliance. Businesses should review their internal processes to ensure all contracts are logged before the filing window.

The Takeaway

From e-invoicing mandates to expanded business permissions, the GCC continues to harmonise and digitise its tax systems. The message is clear: compliance is becoming more integrated, more transparent, and more digital.

At Nishe, we help businesses navigate these transitions, from readiness assessments to system implementation,

 ensuring compliance without disruption.

“It’s just another compliance form — how hard can it be?”

The truth?
It’s not hard, but it’s different — and that’s where most businesses slip up.

Below are the five most common pitfalls we see across UAE businesses — and how you can avoid them.

1. Treating Corporate Tax as a once-a-year task

Corporate Tax isn’t something you can fix at filing time.
It affects your structure, contracts, and daily accounting decisions throughout the year.

We’ve seen companies wait until audit season to “get their numbers ready,” only to discover:

• Related-party transactions weren’t documented properly 
• Adjustments weren’t tracked 
• Taxable income wasn’t calculated the way the FTA requires 

By then, it’s too late to optimise — or worse, you’re left explaining inconsistencies.

The fix:
Make Corporate Tax part of your monthly and quarterly reviews, not just year-end.
That means aligning your chart of accounts, documentation, and decision-making now — not later.

2. Assuming Free Zone = Zero Tax

This is one of the biggest misconceptions in the UAE.
Being based in a Free Zone doesn’t automatically mean you’re exempt.

To qualify for the 0% Free Zone rate, you need to meet strict conditions:

• Generate qualifying income
• Maintain adequate substance (people, assets, activity in the UAE)
• Keep proper accounting segregation between qualifying and non-qualifying income
• Stay compliant with transfer pricing rules

We’ve seen businesses lose their 0% status simply for mixing qualifying and non-qualifying revenue in one ledger.

The fix:
Don’t rely on your trade licence alone — rely on eligibility checks and documentation.
If your income structure is unclear, Nishe can help you review and protect your Free Zone position.

3. Missing the details that matter

Corporate Tax isn’t about ticking boxes — it’s about understanding what the FTA expects from your data.

Simple oversights can trigger penalties:

• Incorrect or incomplete related-party disclosures
  
• Using group assumptions instead of UAE-specific rules
  
• Not reconciling book profits to taxable income correctly 

Most of these errors aren’t deliberate — they happen when finance teams reuse “global templates” without tailoring them for UAE-specific laws.

The fix:
Localise everything.
Your group reporting pack might look fine globally, but it won’t pass an FTA review unless it follows local guidance and Ministerial Decisions.

4. Ignoring Transfer Pricing (until it’s too late)

Transfer pricing isn’t just for large multinationals anymore.
Even small-to-mid-sized groups with intercompany transactions fall under these rules.

That includes:

• Management fees
  
• Shared services
  
• Loans or guarantees
  
• Cross-border supplies within the same group 

We’ve seen businesses fail to prepare proper Transfer Pricing documentation and Local Files, thinking “we’re too small.”
But the FTA expects transparency — and can request these documents at any time.

The fix:
Review your intercompany arrangements now.
Even a simple management charge between two entities should have a pricing policy, a supporting rationale, and a paper trail.

Nishe’s tax team helps businesses build compliant, practical transfer pricing documentation — without unnecessary complexity.

5. Waiting until the deadline to act

Many businesses are taking a “wait and see” approach.
But here’s the reality: the FTA has been clear about enforcement, and penalties are real.

Late filings, inaccurate declarations, or missing data can lead to:

• Monetary fines
  
• Increased audit scrutiny
  
• Suspension of Free Zone benefits

We’ve helped clients who nearly missed deadlines — and it’s a stressful scramble that’s completely avoidable.

The fix:
Start preparing early.
Corporate Tax touches your accounting, systems, and people — it’s not just a form to be filed.
Early planning means fewer surprises and more time to optimise.

The takeaway: Treat Corporate Tax as a business strategy, not a compliance chore

The UAE’s Corporate Tax regime is still new, but it’s here to stay — and those who plan early will gain a real edge.

At Nishe, we work with CFOs, founders, and finance leaders to make Corporate Tax compliance simple, structured, and strategic — so you can stay focused on running your business.

Get in touch with our team for a readiness review or corporate tax consultation.