Self-invoicing and input tax recovery on imported Concerned Goods: the FTA closes the loop on pre-2026 positions
The Federal Tax Authority has issued VATP045, setting out how businesses should have accounted for output tax, issued tax invoices and recovered input tax on Concerned Goods imported into the UAE.
The clarification applies only to Goods imported on or before 31 December 2025, because Federal Decree-Law No. 16 of 2025 removed the self-invoicing obligation for reverse charge imports with effect from 1 January 2026. It is therefore a look-back document, and a timely one for any business with open tax periods, a pending voluntary disclosure, or an FTA audit touching historic imports.
The underlying obligation
A taxable person importing Concerned Goods is treated under Article 48(1) of the Federal Decree-Law No. 8 of 2017 (“VAT Law”) as making a taxable supply to itself, and must account for the due tax. The value and related output tax prepopulated in Box 6 of the VAT return must be reconciled against internal records for the tax period in which the date of supply falls. Where there is a discrepancy, or where an agent imported on the business’s behalf, the correction belongs in Box 7.
Self-invoicing: a practical concession, but a conditional one
Strictly, a registrant treated as supplying goods to itself had to issue a valid tax invoice to itself within 14 days. Recognising the administrative burden, the FTA accepts that no self-invoice was required, and that no administrative exception under Article 59(7)(b) of the Executive Regulation need be applied for, provided the recipient:
• obtained and retained the overseas supplier’s invoice showing the details of the goods and the consideration paid;
• obtained and retained a declaration issued by the relevant Emirate Customs Department showing the details and value of the goods; and
• verified that the correct VAT was prepopulated in Box 6, or made the necessary adjustment in Box 7.
The concession does not apply where either document is missing. Businesses that did issue self-invoices remain obliged to issue tax credit notes to themselves where the related import was subsequently adjusted.
Input tax recovery
Input tax is recoverable to the extent the goods were used, or intended to be used, in making taxable supplies. Critically, the absence of a self-issued tax invoice does not block recovery: the supplier’s invoice and the customs declaration are the documents that matter (Article 48(5) of the Executive Regulation). Recovery falls in the first tax period or the one immediately following in which those documents were obtained and the consideration paid, with payment treated as made where the business intends to pay within six months of the agreed date.
What we suggest you do
• Sample your imports up to 31 December 2025 and confirm that both the supplier invoice and the Emirate customs declaration are on file for each.
• Reconcile Box 6 against internal records for the affected periods.
• Where documentation is incomplete, treat both the invoicing position and the input tax claim as exposed, and consider a voluntary disclosure before the FTA raises it.
• Confirm that self-invoicing has in fact been switched off for imports from 1 January 2026, and that record-keeping has been adapted rather than abandoned.
You can find the Public Clarification here.