JRE · Joshi Real Estate
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UAE input VAT credit rules tighten: supplier due diligence becomes a compliance obligation

New UAE guidance links input VAT recovery to verified supplier standing, raising the compliance bar for all VAT-registered businesses.

# What changed: VAT recovery is now a supplier-knowledge question

The Federal Tax Authority has sharpened its position on input VAT credit: recovering VAT on purchases is no longer simply a matter of holding a valid tax invoice. Gulf News reports that the FTA is directing businesses to verify the VAT registration status, trading legitimacy and invoice accuracy of every supplier before claiming a credit. Where a supplier turns out to be fictitious, deregistered or involved in a missing-trader arrangement, the purchasing business risks losing its input credit entirely, regardless of whether it knew about the irregularity.

This is a meaningful shift in operational exposure. The invoice was previously the primary documentary safeguard. It is still necessary, but it is no longer sufficient.

# Why this matters more than a routine FTA clarification

The timing sits alongside two related pressures. First, Gulf News also notes that the 30 September 2026 deadline for corporate tax returns covering financial year 2025 is approaching fast, placing finance teams under simultaneous filing pressure. A VAT compliance failure identified during a corporate tax audit compounds the exposure considerably.

Second, Crowe's recent analysis of the UAE top-up tax reminds multinational groups that UAE entities are increasingly subject to layered tax obligations. An input VAT dispute adds a further variable to an already complex compliance picture for groups managing transfer pricing and Pillar Two calculations simultaneously.

# The practical risk profile for SMEs

Larger businesses typically run supplier onboarding programmes with KYC-style checks. Smaller and mid-sized companies often do not. A business buying a significant volume of taxable goods or services from suppliers it has never formally verified carries real financial exposure if even one of those suppliers is later found to be improperly registered. The FTA's position, as reported, implies the onus rests with the buyer.

Sector exposure varies. Construction, logistics and trading businesses tend to have long, fragmented supply chains with high VAT throughput, making them the most immediately vulnerable. Professional services firms with simpler procurement are less exposed, but not exempt.

# What to do about it

Audit the current supplier list. Pull the VAT registration number for each active supplier and verify it directly against the FTA's public TRN verification portal. This takes time but is straightforward, and it establishes a documented baseline.

Build verification into onboarding. For any new supplier, confirmation of valid VAT registration should sit alongside trade licence review as a condition of adding them to the payable accounts system. Retain the verification record with date and reference.

Review the last four tax periods. If input VAT has been reclaimed against invoices where supplier verification was not performed, it is worth assessing the volume and identifying any suppliers that look anomalous: newly registered entities, unusually low prices, inconsistent invoice formats. Voluntary disclosure is a tool that exists precisely for this situation, and it carries lower penalties than a post-audit correction.

Coordinate with the corporate tax filing. The 30 September deadline for 2025 CT returns means finance teams are stretched. Prioritise the largest input VAT claims first, not the total number of suppliers.

No business that trades in the UAE can treat VAT recovery as administrative routine any longer. It is a verifiable position that the FTA can and does challenge.

# Sources

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