Article 1 – Definitions of Business Day and Virtual Assets have been included.

Article 2 – Supply of Goods
Supply of real estate now encompasses sale, lease, and any other forms of transfer that result in ownership passing from one person to another.

Article 3 (bis) – Exceptions from Supply of Services
It clarifies that the transfer of ownership or disposal of government buildings, real estate assets, and similar projects between government entities will not be regarded as a supply under UAE VAT law.

Article 5 – Exceptions Related to Deemed Supply
If the total output VAT due for all Deemed Supplies of a taxable person over a 12-month period exceeds AED 2,000, then the VAT amount above AED 2,000 will be classified as output VAT.

Article 8 – Voluntary Registration
A person may only register for tax voluntarily if they can demonstrate to the Authority that they are conducting business in the UAE and intend to make supplies specified in paragraphs (a), (b), or (c) of Clause 1 of Article 54 of the Decree-Law.

Article 14(bis) – Tax Deregistration to Protect the Integrity of the Tax System
The Federal Tax Authority (FTA) has the additional authority to deregister a taxable person if deemed necessary to maintain the integrity of the tax system. This allows the FTA to ensure that individuals or entities no longer meeting taxable person criteria are swiftly removed from the tax register, preventing misuse or non-compliance that could undermine the system’s efficiency and fairness.

Article 15 – Deregistration of a Tax Group or Amendment Thereof
It is clarified that a VAT group member must be removed from the group if, in addition to the situations already specified in the same Article, the member ceases to engage in making taxable supplies.

Article 29 – Profit Margin Scheme
For the Profit Margin Scheme, the purchase price of goods now includes all costs and fees incurred in acquiring the goods alongside the goods’ price.

Article 30 – Export of Goods

• Proof of Export: Article 30 outlines that proof of export may be established through customs declarations, commercial evidence demonstrating export, shipping certificates, and official evidence confirming export, or customs declarations that validate customs duty suspension arrangements if goods are under customs suspension.
• Official Evidence: Documents or clearance certificates certified by competent authorities in the destination country that confirm the entry of goods are also considered official evidence.

Article 31 – Export of Services (Zero-Rated Supplies)

• Services are not supplied directly concerning real estate located in the UAE or improvements to real estate or directly regarding movable assets situated in the UAE at the time services are rendered.
• Under Article 31 (1) (a) (3), services are not considered performed in the UAE or in a Designated Zone as defined in Clauses 3 to 8 of Article 30 and Article 31 of the Decree-Law.
• For paragraph (a) of Clause 1 of Article 31, a person will be deemed “outside the UAE” if their presence in the UAE is less than 30 days and is not effectively connected to the supply.

Article 33 – International Transportation Services for Passengers and Goods (Zero-Rated Supplies)

Transporting goods within the UAE by the same supplier, as part of a service transporting goods from the UAE to abroad or vice versa, qualifies for zero-rating. Services provided to recipients during transportation are also included.

Article 34 – Certain Means of Transport (Zero-Rated Supplies)

Ships, boats, or floating structures designed or adapted for commercial transportation of passengers and goods, not meant for recreation, pleasure, or sports, qualify for zero-rating.

Article 35 – Goods and Services in Connection with Means of Transport (Zero-Rated Supplies)

The following services directly associated with means of transport for operational, repair, maintenance, or conversion purposes are zero-rated:

• Repair services if conducted onboard the means of transport.
• Maintenance services performed onboard, including inspection, testing, cleaning, repainting, and similar services.
• Conversion services, provided the means of transport continues to meet the stipulations of Article 34 after conversion.

Article 35 – Residential Buildings

Residential buildings do not encompass hotel apartments or serviced apartments or similar properties.

Article 38 – Buildings Specifically Designed for Charities
The meaning of “relevant charitable activity” has been removed from the Executive Regulation by the Authority.

Article 41 – Healthcare Services
A supply of goods or import of concerned goods is zero-rated if it involves:
Any pharmaceutical products as determined by a Cabinet decision. Any medical equipment as specified by a Cabinet decision. Other goods not covered under paragraphs (a) and (b) of this Clause, which are supplied while providing zero-rated healthcare services necessary for such healthcare service supply.

Article 42 – Tax Treatment of Financial Services
Article 42 (2) now includes the following in the definition of financial services:

• Management of investment funds, meaning services provided by fund managers for consideration to funds licensed by competent authorities in the State, including but not limited to fund operation management, investment management, and fund performance monitoring.
• Transfer of ownership of virtual assets, including virtual currencies.
• Conversion of virtual assets.
• Management and custody of virtual assets, allowing for control.
  Moreover, Article 42(3) exempts the following services from VAT:
  • Fund management services
  • Transfer of ownership of virtual assets, including virtual currencies.
  • Conversion of virtual assets.

Article 46 – Tax on Supplies of More Than One Component
Article 46(1)(b) has been updated to clarify that if a single composite supply lacks a principal component, tax treatment should generally apply based on the overall nature of the supply.

Article 53 – Non-Recoverable Input Tax

• 1(c) Goods or services purchased for employee use without charge, for personal benefit including entertainment services, are considered non-recoverable, except in the following cases:
  If providing those goods or services to employees is a legal obligation under applicable labor law in the State or Designated Zone.
• If it is a contractual obligation or documented policy to provide those goods or services for employees to perform their roles, proven as normal business practice.
• Where a taxable person provides health insurance, including enhanced coverage, to employees and their family members (applying to one spouse and three children under 18). If the provision of goods or services constitutes a deemed supply per Decree-Law provisions.

Article 55 – Apportionment of Input Tax
Taxable persons can now seek FTA approval to utilize a fixed apportionment recovery rate derived from the previous tax year’s rate. Additionally, new conditions have been introduced for proportionally adjusting the annual adjustment threshold of AED 250,000 when the tax year is shorter than 12 months.

Article 59 – Tax Invoices
It emphasizes that tax amounts must be stated in AED on simplified invoices. It also outlines the timeline for issuing tax invoices, indicating that simplified tax invoices must be issued on the supply date, and summary tax invoices should be issued to recipients within 14 days of the end of the calendar month in which the supply date falls.

Article 60 – Tax Credit Note
In cases where multiple tax credit notes are issued for a single tax invoice, it is crucial to ensure that the value of the supply indicated on each subsequent tax credit note is adjusted according to the values established in previous tax credit notes.