Key takeaways
- Exports of goods from the UAE to outside the VAT-implementing states are zero-rated under Article 45 of Federal Decree-Law No. 8 of 2017, which means an exporter charges 0% VAT, not no VAT: the sale is still a taxable supply that goes on the VAT return.
- For goods, the 0% rate holds only if the goods physically leave the UAE (or enter a customs suspension arrangement) within 90 days of the date of supply and the exporter keeps the evidence the Executive Regulation requires; if not, the supply is taxed as a domestic sale at 5%.
- A UAE service provider can zero-rate a service as an export only if the client has no place of residence in the UAE, is outside the UAE while the service is performed, and the service isn't directly connected to UAE real estate or to movable assets located in the UAE.
- Zero-rated exports still count towards the AED 375,000 mandatory VAT registration threshold (as of November 2026), so an exporter can't avoid registering because every sale is at 0%.
- Cabinet Decision No. 100 of 2024 changed the export evidence rules from 15 November 2024; Cabinet Decision No. 149 of 2026 amends other parts of the VAT Executive Regulation and, in the summaries checked, leaves the export rules alone.
Are exports zero-rated for UAE VAT?
Yes. Article 45 of Federal Decree-Law No. 8 of 2017 applies the zero rate to the direct or indirect export of goods to outside the VAT-implementing states, and the Executive Regulation (Cabinet Decision No. 52 of 2017, as amended) extends the same treatment to qualifying exported services.
Zero-rated is not exempt: you still register, issue tax invoices and report the sale on your VAT return through EmaraTax, and because the supply is taxable you can generally recover input VAT on the related costs. When an export fails the tests below, the standard 5% rate applies: that is the tax treatment of a domestic sale.
What proof do I need to zero-rate an export of goods?
You need one of three evidence sets, and you must be able to produce it if the FTA asks. Since 15 November 2024, Article 30 of the Executive Regulation, as amended by Cabinet Decision No. 100 of 2024, accepts any one of the combinations below.
| Evidence set | What it consists of |
|---|---|
| 1 | Customs declaration plus commercial evidence proving the export |
| 2 | Shipping certificate plus official evidence proving the export |
| 3 | Customs declaration proving a customs duty suspension arrangement |
Official evidence includes export certificates from UAE customs or clearance certificates confirming the goods left or arrived. Commercial evidence means transport documents such as an airway bill, bill of lading or land transport bill. Before the amendment, only an exit certificate from the local Emirate's customs department was accepted, so older record-keeping habits may leave gaps. The evidence has to identify the supplier, the consignor, the goods, their value, the destination, and the mode and route of transport.
How does the 90-day rule for exported goods work?
Goods must be exported, or placed under a customs suspension arrangement, within 90 days of the date of supply (as of November 2026) for the 0% rate to apply. If they aren't, the supply is taxed at the rate that would apply to a domestic sale.
90 days: the period from the date of supply within which exported goods must leave the UAE for the sale to stay zero-rated. Source: Cabinet Decision No. 52 of 2017 (VAT Executive Regulation), Article 30, as amended; checked 08 November 2026.
The FTA can extend the period on written application where circumstances beyond the parties' control prevent export in time, or where the nature of the supply makes export impracticable. Ask before day 90, not after.
For an indirect export, where the overseas buyer collects the goods or arranges the shipping, the buyer must obtain the export evidence and hand you a copy. The goods must not be used or altered before export except to prepare them for it, and they can't leave the UAE with a passenger or crew member.
When are exported services zero-rated?
A service is zero-rated as an export when the recipient has no place of residence in a VAT-implementing state and is outside the UAE while the service is performed. The service also can't be directly connected to UAE real estate or to movable assets located in the UAE when it's performed.
The FTA's public clarification VATP019 reads the tests this way:
- Residence: a company is resident where it has a place of establishment or a fixed establishment; if the client has several, the one most closely related to the supply decides.
- Location: the test is the client's physical presence while the service is performed and consumed; presence before or after doesn't count.
- Short visits: a person in the UAE for under one month, where the presence isn't effectively connected with the supply, is still treated as outside the UAE.
Since 15 November 2024, Article 31 of the Executive Regulation adds a further condition: the service must not be one whose place of supply falls inside the UAE under the special place-of-supply rules in Articles 30 and 31 of the Decree-Law. Real estate-related, electronic and telecommunications services are the usual casualties.
Do sales to Saudi Arabia, other GCC states and designated zones count as exports?
A sale of goods to a customer in another GCC country can qualify as an export, because the FTA's position in VATP019 is that the UAE does not currently treat any other GCC state as a VAT-implementing state. Movement of goods into a designated zone is a different case: the Executive Regulation says it isn't treated as an export.
Designated zones have their own rules, set out in the FTA's Designated Zones VAT guide; check your zone against it before invoicing at 0%. A free zone company outside a designated zone is treated as a normal UAE business for VAT.
How do I invoice and report a zero-rated export?
Issue a tax invoice that shows the supply at the zero rate, collect the export evidence, and report the sale as a zero-rated supply on your VAT return in EmaraTax.
- Confirm where the customer is established and, for services, where they are while the work is done.
- Agree in writing at or before the sale who arranges shipping, and, for an indirect export, that the buyer will send you the export evidence.
- Issue the tax invoice at the zero rate.
- Diary day 90 from the date of supply and chase the evidence well before it.
- File the VAT return in EmaraTax with the sale in the zero-rated supplies line, and keep the evidence with your VAT records.
If you'd rather not track these dates by hand, the free UAE compliance calendar lists them for your company.
What changed recently?
The export evidence and services tests changed on 15 November 2024; the 2025 and 2026 instruments below don't change the zero-rating tests in the summaries checked.
| Date | Instrument | Effect on exports |
|---|---|---|
| 15 November 2024 | Cabinet Decision No. 100 of 2024 | Three accepted evidence sets for goods; new place-of-supply condition for services |
| 1 January 2026 | Federal Decree-Law No. 16 of 2025 | Reverse charge self-invoices dropped; five-year limit on reclaiming excess refundable tax; no change to export zero-rating reported |
| 1 October 2026 (most provisions, per a KPMG summary) | Cabinet Decision No. 149 of 2026 | Changes to medical products, apportionment, composite supplies and cash payments; export rules not mentioned in the summaries |
What most guides don't tell you
- The 90 days run from the date of supply, which isn't always the invoice date. If you take a deposit or invoice early, the tax point rules can fix the date of supply sooner than you expect, so check your tax point when lead times are long.
- With an indirect export, the missing paperwork is your problem. The overseas buyer collects the evidence, but if it never arrives, the sale is taxed at 5% and the VAT is yours to pay. Make the evidence a condition of the deal.
- A hand-carried shipment doesn't count. Goods leaving in a passenger's or crew member's baggage are outside the indirect export rules, however clear the buyer's intent.
- For services, the burden of proof sits with you. Under the FTA's VATP019 reading, if you can't establish that the client is non-resident and outside the UAE during performance, you must charge 5%. A client's representative attending a hearing or workshop in the UAE during delivery can be enough to lose the zero rate.
Which VAT deadlines apply to your company?
Zero-rating holds only if the returns, the evidence and the 90-day diary are all on time. The UAE compliance calendar is a free calendar of your company's UAE tax and compliance deadlines, personalised from a few questions, as a PDF and calendar file.
Frequently asked questions
What is zero-rated vs exempt supply in UAE VAT?
A zero-rated supply is taxable at 0%, so you report it on your VAT return and can generally recover the input VAT on related costs. An exempt supply, such as financial services or bare land, is outside the VAT charge and does not carry that recovery right.
Is VAT charged on services to foreign clients?
Not always. A service is zero-rated only if the client has no place of residence in the UAE, is outside the UAE while the service is performed, and the service isn't tied to UAE real estate or movable assets located in the UAE; otherwise it is taxed at 5%.
How does the reverse charge mechanism work in the UAE?
When a UAE VAT-registered business buys taxable goods or services from a foreign supplier, it accounts for the VAT itself on its own return instead of the supplier charging it. From 1 January 2026, under Federal Decree-Law No. 16 of 2025, it no longer has to issue a self-invoice but must still keep supporting documents.
Do I charge VAT to a free zone company?
It depends on whether the customer sits in a designated zone. A free zone company outside a designated zone is treated like any other UAE business, so you charge 5% unless a zero rate applies; designated zones have their own rules for goods, so check the FTA's Designated Zones VAT guide before invoicing at 0%.
About Qawi · Qawi is a corporate services firm licensed in the Sharjah Media City (SHAMS) free zone, handling company formation, visas and PRO, bookkeeping, VAT and corporate tax for UAE businesses. Guides are researched from FTA, Ministry of Finance and free zone sources. Qawi on LinkedIn
Sources
Official and legislative sources:
- Federal Decree-Law No. 8 of 2017 on Value Added Tax, Articles 1, 45 and 46 (UAE Legislation portal)
- Cabinet Decision No. 52 of 2017 and its amendments, VAT Executive Regulation, Articles 30 and 31 (FTA)
- Guidance on Zero-Rated and Exempt Supplies (u.ae)
- Ministry of Finance: VAT law amendments from January 2026 (Federal Decree-Law No. 16 of 2025)
- Ministry of Finance: amendments to the VAT Executive Regulation (Cabinet Decision No. 149 of 2026)
- FTA Designated Zones VAT Guide
- FTA Public Clarification VATP019, zero-rating of export of services (published by the FTA; read via a third-party copy at vatupdate.com)
Professional-firm summaries used only to interpret the 2024 and 2026 amendments:
- KPMG: Update to the UAE VAT Executive Regulation (Cabinet Decision No. 100 of 2024)
- PwC: UAE VAT Executive Regulation amendments (2024)
- KPMG: Cabinet Decision No. 149 of 2026
Last checked: 08 November 2026
This is general information, not tax or legal advice for your specific situation.