The Federal Tax Authority issued VAT Public Clarification VATP045 on 26 August 2026, and it only applies to one specific situation: goods you imported into the UAE from outside the country on or before 31 December 2025. If your business only started importing goods this year, VATP045 doesn’t change anything for you. If it imported goods before that date, though, this clarification tells you exactly what documentation the FTA expects you to have on file.
VATP045 sets out how Taxable Persons must account for Output Tax, when they were required to issue themselves a Tax Invoice, and what supporting documents they need to recover the related Input Tax on these “Concerned Goods.” It’s essentially a closing statement on a rule that no longer applies going forward, written so businesses can settle their pre-2026 records with confidence.
What Are "Concerned Goods" Under UAE VAT Law?
Article 1 of the VAT Law defines Concerned Goods as goods that have been imported into the UAE and would not be exempt from VAT had they been supplied within the country. In practice, this covers a wide range of purchases: spare parts, machinery, raw materials, equipment, and most other physical goods brought in from overseas suppliers.
The FTA treats a business that imports Concerned Goods as if it made a taxable supply to itself. That single concept under Article 48(1) of the VAT Law drives every requirement in VATP045 – the Output Tax obligation, the (former) self-invoicing rule, and the Input Tax recovery conditions.
Why VATP045 Only Covers Imports Made Before 1 January 2026
This is the detail that trips people up. The VAT Law was amended, and from 1 January 2026 onward, Taxable Persons are no longer required to issue Tax Invoices to themselves when importing Concerned Goods. The self-invoicing obligation that VATP045 describes in detail has effectively been retired for current transactions.
VATP045 exists to close out the transitional period. It applies only to Concerned Goods imported on or before 31 December 2025, giving businesses a clear reference for how those older imports should have been treated and what they still need to keep on file to defend Input Tax claims.
Your Obligation to Account for Output Tax on Imported Goods
For any import made before 1 January 2026, a Registrant (referred to in the clarification as the “Recipient”) that imported Concerned Goods had to account for Output Tax on the value of those goods, treating the import as a supply to itself.
That Output Tax value should already sit in Box 6 of the relevant VAT Return, prepopulated based on customs data. However, the FTA places the responsibility on the Taxable Person to reconcile that prepopulated figure against internal records for the Tax Period in which the date of supply falls.
If you spot a discrepancy – or if a customs agent imported goods on your behalf rather than you doing so directly an adjustment belongs in Box 7 of the same return, not a quiet correction elsewhere.
Did You Need to Issue Yourself a Tax Invoice?
Under the pre-2026 rules, a Registrant supplying Concerned Goods to itself was required to issue and deliver a valid Tax Invoice to itself within 14 days of the date of supply, exactly as if it were invoicing another party.
The FTA recognized early on that this created an unnecessary administrative burden, so it built in an accepted exception. A Recipient did not need to issue itself a Tax Invoice, and did not need to apply for an administrative exception separately, provided it met three conditions:
- It obtained and retained the overseas supplier’s invoice, showing the details of the Concerned Goods and the consideration paid.
- It obtained and retained a declaration from the relevant Emirate Customs Department, showing the details and value of the Concerned Goods.
- It verified that the correct VAT amount was prepopulated in Box 6 of the VAT Return, or made the necessary adjustment in Box 7.
If a business didn’t hold both the supplier invoice and the customs declaration, this relief didn’t apply, and it would have needed a formal administrative exception under Article 59(7)(b) of the VAT Executive Regulation to avoid issuing a self-invoice. Businesses that did issue themselves Tax Invoices, meanwhile, are also required to issue themselves Tax Credit Notes for any later adjustment to those Concerned Goods.
Recovering Input Tax on Concerned Goods
This is the part with real financial stakes, because it determines whether an Input Tax claim survives an FTA audit. A Recipient can recover the Input Tax related to Concerned Goods to the extent those goods were acquired to make Taxable Supplies, provided two conditions are met: the Recipient is VAT-registered, and it holds the relevant supporting documents.
Crucially, VATP045 confirms that a business remains eligible to recover Input Tax even if it never issued itself a Tax Invoice, as long as it retains the overseas supplier’s invoice and the Emirate Customs declaration. The self-invoice was never the document that mattered most for recovery purposes – the underlying supplier and customs paperwork was.
Timing matters too. Input Tax should be recovered in the first Tax Period, or the Tax Period immediately following, in which the Registrant obtained the relevant supporting documents and paid the consideration. For recovery purposes, a business is treated as having paid the consideration if it pays, or intends to pay, within six months of the agreed payment date.
What This Means in Practice: A Legacy Review Worth Doing
Because VATP045 only looks backward, the real action item is a documentation check, not a change to how you currently process imports. If your business imported goods before 1 January 2026, it’s worth running through this before your records get pulled into an audit or refund review:
- Locate the paperwork for each pre-2026 import. For every relevant transaction, confirm you hold both the overseas supplier’s invoice and the Emirate Customs declaration.
- Check whether a self-invoice was actually required. If you’re missing either the supplier invoice or the customs declaration, the automatic relief didn’t apply, and you should confirm whether a Tax Invoice was issued or whether an administrative exception was obtained.
- Reconcile Box 6 and Box 7. Compare the Output Tax values prepopulated by the FTA against your internal import records for the relevant Tax Periods, and confirm any necessary Box 7 adjustments were made at the time.
- Confirm your Input Tax recovery timing. Verify that Input Tax was claimed in the correct Tax Period, based on when the supporting documents were obtained and the consideration was paid or intended to be paid.
- Retain everything under the e-invoicing rules. Where a Tax Invoice was issued or is required to be issued in electronic format, it needs to be retained in line with the Electronic Invoicing System.
A gap in any of these areas doesn’t necessarily mean an Input Tax claim is invalid, but it does mean the claim is harder to defend if the FTA asks for evidence later.
Frequently Asked Questions
Does VATP045 apply to goods I'm importing now?
No. VATP045 only covers Concerned Goods imported on or before 31 December 2025. From 1 January 2026, Taxable Persons are no longer required to issue Tax Invoices to themselves on the import of Concerned Goods.
What's the difference between VATP045 and VATP044?
VATP044 addresses Concerned Services (things like imported consulting or software services under the reverse charge mechanism), while VATP045 addresses Concerned Goods (physical items brought into the UAE). The underlying self-supply principle under Article 48(1) is the same for both, but goods and services are reported and documented separately.
Can I still recover Input Tax if I never issued myself a Tax Invoice?
Yes, provided you retained the overseas supplier’s invoice and a declaration from the relevant Emirate Customs Department, and you meet the other standard recovery conditions.
What happens if I'm missing the supplier invoice or customs declaration?
The automatic exception from self-invoicing doesn’t apply in that case. You would need to have obtained a formal administrative exception from the FTA under Article 59(7)(b) of the VAT Executive Regulation, or you may have been required to issue a Tax Invoice to yourself.
Which VAT Return box do I use to adjust Output Tax on imported goods?
Box 6 is prepopulated with the Output Tax value based on customs data. If you identify a discrepancy or if an agent imported goods on your behalf, the adjustment goes in Box 7.
How long do I have to recover Input Tax on Concerned Goods?
Generally, in the first Tax Period, or the Tax Period immediately following, in which you obtained the relevant supporting documents and paid – or intended to pay within six months of the agreed date – the consideration.
Do spare parts and machinery count as Concerned Goods?
Yes. The FTA specifically lists spare parts, machinery, and other goods imported into the UAE as examples of Concerned Goods.
Getting Your Pre-2026 Import Documentation in Order
VATP045 rewards businesses that already keep clean records and creates work for those that didn’t. If your VAT filings include imported goods from 2024 or 2025 and you’re not fully confident every supplier invoice, customs declaration, and Box 6/7 adjustment lines up, a focused review now is far less costly than resolving it during an FTA audit or a VAT refund request.
NR Doshi & Partners‘ VAT advisory team regularly runs exactly this kind of legacy documentation review for import-heavy businesses across the UAE. If you’d like a second set of eyes on your Concerned Goods records, get in touch with our VAT team for a consultation.
Author:
This article was prepared by the VAT advisory team at NR Doshi & Partners, an FTA-approved chartered accountancy and business advisory firm operating across the UAE since 1985.
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