An electronic invoice is not automatically a tax invoice, and keeping it electronically is now tied to your input tax

FTA Public Clarification VATP046, published 4 September 2026, explains amendments made by Federal Decree-Law No. 16 of 2024 and No. 16 of 2025. Four points matter if you are heading into UAE e-invoicing. First, the law now defines an Electronic Invoicing System, an Electronic Invoice and an Electronic Credit Note, and an electronic invoice does not automatically count as a Tax Invoice. It only counts as one if it meets Articles 59 and 60 of the Executive Regulation. Second, under Article 55, once you are inside the Electronic Invoicing System you have to keep your tax invoices in electronic form in order to deduct input tax. Filing a printed copy is not the route to the deduction. Third, and this one applies today rather than at your go-live date, new Article 54 bis lets the FTA refuse an input tax deduction where the supply or the supply chain is connected with tax evasion and you knew or should have known. Not checking that a supply was genuine can count as should have known, and the verification measures are set out in FTA Decision No. 13 of 2026. Fourth, from 1 January 2026, if you import concerned goods or concerned services you no longer issue a self-tax invoice under the reverse charge. You still account for the VAT and keep the supporting documents. Imports before that date stay under the older clarifications VATP044 and VATP045.

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