How to Claim the Administrative Exceptions Benefits Under the UAE VAT and the Eligibility Criteria?

The UAE has been known for its tax-friendly environment, which it has been maintaining for more than a decade, and hence it has now become one of the best business lands for the businesses from around the world. In order to enhance the tax structure and to provide further tax aids to the businesses, the FTA and the UAE’s authorities have been implementing several tax exceptions and amendments in favour of the businesses. A VAT administrative exception is one such kind of implementation which provides the registrants with concessions and exceptions allowed under the VAT law and the executive regulations. In this blog you will get to know the eligibility criteria for the VAT administrative exceptions and the process to apply for the same.

The Eligibility Criteria

As per the VAT administrative exceptions guide, VAT Administrative Exceptions Guide - EN - 05 12 2025.pdf, only the specified persons can apply for the administrative exceptions. In general, only the registrants are allowed to apply for the exceptions, which would normally include the taxable persons who are issued with the TRN under the VAT. The request is allowed to be filled by the following entities:

• Any authorised signatory who has been appointed by the registrant or the registrant himself can apply for the exceptions under the instance of being a natural person.
• Any tax agent who has been appointed by the registrant
• Or any legal representative who has been appointed by the court of law.

Further, it should be kept in mind that the tax agent must be the person who has been listed as the tax agent for the indirect taxes and not the direct taxes. If the tax agent is listed under both the direct and indirect tax agents, along with meeting the further requirements, then he can apply on behalf of the registrant.

The Eligible Cases

Under the executive regulation there are certain specific cases for which the registrants can apply for the administrative exceptions under the VAT. These cases include the following:

• Tax invoices: If the registrant makes the request to not be required to reflect all the particulars specified as per the certain executive regulations in the tax invoices while issuing it or requests not to be required to issue tax invoices in certain cases, then that would be allowed under the administrative exceptions if the conditions are met.
• Tax Credit notes: If the registrant makes the request to not be required to reflect all the particulars specified as per the certain executive regulations in the tax credit notes while issuing it or requests not be required to issue tax credit notes in certain cases, then that would be allowed under the administrative exceptions if the conditions are met.
• Evidence to prove the export of goods: If a registrant requests to be allowed to use other documentary evidence in place of the evidence to prove the export of goods to prove that the export has been carried out, or if the FTA specifies any alternative form of evidence based on factors such as the nature of the business in order to prove the export of the business, then that would be allowed if the certain conditions as per the guide are met.
• Time to export goods: If the registrant requests a 90-day extension in order to export the goods from the UAE, then that would be allowed if the conditions are met as per the guide.

The Conditions to be Met for Each Case

There are certain conditions that are to be met in order to get the exceptions processed, which include the following as per the guide:

• Tax invoices and tax credit notes: Sufficient records and documents which can be used to establish the particulars of the supply made. Also, the registrant should provide reasonable justification regarding why it can be impractical to issue the tax invoice or the credit notes in certain circumstances
• Evidence to prove the export of goods: The registrant must be able to provide accurate reasons for why such a document is not available or cannot be obtained, and also the sample of the documents that would be used instead must be provided.
• Time to export goods: As per the guide, the registrant must provide the proper evidence that the reason for the delay in delivery of the goods, which results in delivery beyond the 90-day period, is due to circumstances that are beyond the control of either the supplier or the recipient or both. Also, there must be proof that, based on the nature of the supply of goods, it is not possible to deliver within the 90-day period.

The Process to Apply for the Administrative Exception

As per the VATGEX1 guide, the following are the procedures to be followed to apply for the exception request:

• The registrant must access the EmaraTax account dashboard first.
• Next, the registrant must click on the “View” option to access the “Taxable Person Account".
• Next, click on the “VAT” option on the right side and then choose the “Other Services” option.
• Again, click on the “View” option under the “VAT Administrative Exceptions".
• The last step is to click on “New Request” and then on “Proceed” and complete the application.

How Can CDA Assist with the VAT Administrative Exception?

CDA has been serving the clients in the UAE for more than a decade, which has made it one of the leading accounting, auditing and tax consultancy firms. The professional experts being aware of all the prevailing tax regulations and amendments can assist the clients in identifying the eligibility for the exceptions and also assist in applying for the request for the exception. The professional assistance would further enable the clients to reduce errors and chances of rejection of the application.

To know more about the services, connect with our experts today!

Mitesh Maithia

Tax Manager

Mitesh is a Tax Professional with expertise in direct, indirect, and international taxation, including transfer pricing, since 2018. Passionate about making complex tax matters simple, he shares insights to help businesses stay compliant and forward-looking.