UAE Import, Customs and Import VAT in 2026: the Customs Client Code, Mirsal 2, 5% on CIF, Designated Zones and Recovering Import VAT

Bringing goods into the UAE runs through two independent circuits: customs and tax. The customs circuit is run by the emirate — importer registration, the declaration, 5% duty on the CIF value. The tax circuit is run federally — 5% VAT on a base that includes the duty, with the option of not paying it at the border if the tax registration number is linked to the customs registration number. The two circuits meet at exactly one point, and that point is the one most often left unconfigured.

Three things that have changed and are barely covered anywhere.

One: from 3 August 2026 the duty-free threshold for cross-border e-commerce in Dubai has been raised to AED 1,000. It was set by Dubai Customs Customs Notice No. 16/2026 of 30 July 2026, amending Notice No. 15/2021. The exemption does not extend to tobacco and tobacco products, electronic nicotine delivery systems, devices and accessories, nicotine-containing liquids, alcoholic beverages, or food preparations containing alcohol.

Two: from 14 April 2026 the entire structure of the late-payment penalty changed. Cabinet Decision No. 129 of 2025, dated 9 October 2025, rewrote the administrative penalties table: in place of the previous combination of a fixed percentage and a monthly uplift, late payment now carries a monthly penalty accruing at an annual rate of 14 per cent, running from the day after the payment due date. The fixed-percentage-plus-monthly model survives, but only for voluntary disclosures filed late.

Three: from 1 October 2026 Federal Tax Authority Decision No. 13 of 2026 takes effect, setting out the checks a taxable person must perform on its supplier before deducting input tax. Failing to perform them is itself treated as establishing that the taxable person should have known of tax evasion in the chain, under the new Article 54 bis of the VAT Law.

The Legal Framework: Five Layers That Must Not Be Merged

Import regulation in the UAE sits in five layers, and each one builds on the layer below rather than replacing it.The costliest single error is treating customs rules and VAT rules as one body of law.

Layer	Instrument	What it governs
1. Supranational	The Common Customs Law of the GCC States and its Rules of Imple­menta­tion — approved at the 20th session of the GCC Supreme Council on 27–29 November 1999, amended at the 22nd session on 30–31 December 2001, in force from January 2002	Customs procedure, valuation, duty suspension, exemptions
2. Federal ratifying	Federal Decree No. 85 of 2007 approving the GCC Common Customs Law and its Rules of Imple­menta­tion (Official Gazette No. 471 of 30 September 2007)	Bringing the Common Customs Law into UAE domestic law
3. Federal institutional	Federal Decree-Law No. 14 of 2021 establishing the Federal Authority for Identity, Citizenship, Customs and Port Security (issued 25 August 2021, Official Gazette No. 709 of 26 August 2021, in force 27 August 2021)	Article 15 repealed Federal Law No. 8 of 2015 on the Federal Customs Authority; Article 2(2) transferred all of its competences to the new authority
4. Federal tax	Federal Decree-Law No. 8 of 2017 on Value Added Tax(issued 23 August 2017, in force 1 January 2018) with three amendments, and Cabinet Decision No. 52 of 2017 (the Executive Regulation) with six amendments	The VAT rate on import, the base, reverse charge, Designated Zones, recovery
5. Emirate operational	The customs notices and policies of the individual emirate’s customs department — for Dubai, Dubai Customs Customs Notices and Dubai Customs Policies	Importer registration, declaration types, fees, guarantees, inspections

There is no Federal Customs Authority as a separate body in 2026. Federal Law No. 8 of 2015 on the Federal Customs Authority was repealed by Article 15 of Federal Decree-Law No. 14 of 2021, and Article 2(2) of the same decree-law transferred every competence and power to the Federal Authority for Identity, Citizenship, Customs and Port Security (ICP). Execution nonetheless remains at emirate level: all seven emirates operate their own customs departments.

The federal repeal chain runs as follows. Federal Law No. 1 of 2003 establishing the Federal Customs Authority was repealed by Article 22 of Federal Law No. 8 of 2015, and Federal Law No. 8 of 2015 was in turn repealed by Article 15 of Federal Decree-Law No. 14 of 2021. Note the instrument type: No. 8 of 2015 is a federal law, not a decree-law; that is how the repealing provision names it.

ICP’s own register of legal instruments is out of date, and it is a trap for anyone citing it. As at August 2026 its Legal Affairs page still lists among the instruments in force Federal Law No. 1 of 2003 — repealed in 2015 — and Federal Law No. 13 of 2007 on commodities subject to import and export control, which was expressly repealed by Article 30 of Federal Decree-Law No. 43 of 2021 on Goods Subject to Non-Proliferation (in force 2 January 2022). Author’s assessment: that register cannot be used as a source of law in force — the instrument record on the legislation portal has to be checked instead.

One divergence over the ratifying instrument should be recorded honestly. A level 2 secondary source — a publication by an international law firm — reports a Federal Decree No. 15 of 2022 ratifying the GCC Common Customs Law and its Rules of Implementation and said to have repealed Federal Decree No. 85 of 2007. The existence of such an instrument could not be confirmed from any official source: it appears neither on the legislation portal nor in ICP’s register, and ICP’s register as at August 2026 continues to name Decree No. 85 of 2007 as the operative instrument. This analysis therefore uses Decree No. 85 of 2007 as the safer citation, while recording the divergence.

The VAT Law amendment chain has three links, and the last one is almost never reflected in commentary.

Instrument	Issued	In force
Federal Decree-Law No. 8 of 2017	23 August 2017	1 January 2018
Federal Decree-Law No. 18 of 2022	26 September 2022	1 January 2023
Federal Decree-Law No. 16 of 2024	30 September 2024	30 October 2024
Federal Decree-Law No. 16 of 2025	1 October 2025	1 January 2026

Federal Decree-Law No. 16 of 2025 is the most consequential change for importers in three years. It inserted Article 54 bis into the VAT Law, giving the tax authority the power to refuse an input tax deduction; it removed the requirement to issue a self-invoice when applying the reverse charge (by amending Article 48(1)); and it introduced a five-year limit on reclaiming excess tax. The Ministry of Finance announced the amendments on 3 December 2025.

The Executive Regulation chain has six links.

Instrument	Issued	In force
Cabinet Decision No. 52 of 2017	26 November 2017	1 January 2018
Cabinet Decision No. 46 of 2020	4 June 2020	4 June 2020
Cabinet Decision No. 24 of 2021	11 March 2021	1 January 2018 (retrospective)
Cabinet Decision No. 88 of 2021	28 September 2021	30 October 2021
Cabinet Decision No. 99 of 2022	21 October 2022	1 January 2023
Cabinet Decision No. 100 of 2024	6 September 2024	15 November 2024
Cabinet Decision No. 100 of 2025	12 August 2025	29 September 2025

A common error in commentary sits here. Article 51 of the Executive Regulation — the Designated Zones provision — was amended by Cabinet Decision No. 88 of 2021 (clauses 5 to 10), not by Cabinet Decision No. 100 of 2024. The Federal Tax Authority’s public clarification VATP040, which is devoted to the 2024 amendments, contains no mention of Designated Zones at all. Author’s assessment: material that attributes changes to the free zone regime to the 2024 decision is working from summaries, not from the text.

A note on source access. The tax.gov.ae portal closes part of its file store to automated retrieval on the canonical path; the texts of the laws, regulations and decisions used here were read directly from the consolidated publications of the Federal Tax Authority and the Ministry of Finance. Dubai Customs notices were read from the official PDFs on the customs department’s own domain. The GCC Unified Customs Tariff schedule itself could not be obtained as a standalone document — rates are cited from UAE federal statutes and official portals, and this is flagged in the relevant sections.

What the Customs Client Code Is and Who Needs One

The customs client code is the registration number of a trader in the customs department’s system in a given emirate. In Dubai the official name of the service is Request Business Registration, and the identifier itself is officially called the Business Code.

The terminology here is more confused than anywhere else in the procedure. “Importer code”, “customs code”, “client code” and “IEC” are trade jargon. The official terms differ by emirate and by authority:

Who	Official term
Dubai Customs	Business Code (service: Request Business Registration; on the portal: Client Registration)
Federal Tax Authority (FTA)	Customs Registration Number (CRN)
Abu Dhabi Customs	Customs Registration Number (service: Issue Customs Registration Number, via the TAMM platform)
Sharjah Customs	Importer/agent code
Ajman Customs	Importer Code

Dubai Customs states the obligation as broadly as it can be stated: any business that uses Dubai Customs services must register with Dubai Customs. The target group for the service in the official service guide is given as “Companies”.

The practical consequence is that the code is needed by whoever lodges the declaration in its own name. A company working through a licensed customs broker clears under the broker’s code. That is lawful and common, but it carries a tax consequence analysed below: where someone else’s customs number appears on the declaration, the mechanism that carries import VAT into the importer’s own return does not fire automatically.

The categories are not “importer” and “exporter” but nine groups. The official Dubai Customs list: Trading (Importer/Exporter), Non-Trading (Professional, Service, Government, Charity and similar), Customs Brokers, Shipping/Air Line, Clearing and Forwarding, Free Zone, Customs Warehouses (private and public), Courier, Cargo Handlers. There is no separate import code and export code: Trading covers both.

Cost and timing — the figures most often misquoted.

Item	Amount	Note
New Business Code registration	AED 100	plus the Knowledge and Innovation fee
Knowledge and Innovation fee on registration	AED 20	added to any service costing AED 50 or more
Total for a new registration	AED 120
Renewal	AED 25	the Knowledge and Innovation fee is not added, the amount being below the AED 50 threshold
Total for a renewal	AED 25
Adding a new business type	AED 100
Amendment of details	no fee
Processing time	1 working day	for both registration and renewal

Renewing a Dubai Business Code costs AED 25 — not AED 100 and not AED 120. The knowledge and innovation rule reads, verbatim: “AED 20 Knowledge and Innovation fees will be added on top of any service costs AED 50 and above”. Renewal at AED 25 sits below that threshold, so no fee is added.

Documents for a new registration: a copy of the trade licence, a copy of the authorised person’s passport, and a copy of the Emirates ID. The Courier category additionally requires an Emirates Post licence; professional companies require an Undertaking Letter. Renewal requires only the trade licence copy.

The Business Code’s validity is tied to the trade licence, not to the calendar — and this is the most common planning error. Dubai Customs states it verbatim: “The validity of this Business code is associated with the validity of the License. Clients can request for the renewal of the business code only after the renewal of the License from the competent licensing authority.” The practical consequence: the customs code cannot be renewed before the licence has been renewed. A company whose licence renewal slips automatically loses the ability to lodge declarations in its own name — and finds out when the container is already at the port. The statement that “the code is valid for 12 months” is wrong as a rule of law: it is valid for exactly as long as the licence is. Dubai Customs’ official resources publish no information about any grace period after expiry, and none is asserted here.

The code is issued by the emirate and applied for through the emirate’s portal. In Dubai through Dubai Trade (www.dubaitrade.ae); in Abu Dhabi through the TAMM platform; in Sharjah through the customs department’s own e-Portal; in Ajman through the Trade Portal and the ENJAZ portal. Ras Al Khaimah, Fujairah and Umm Al Quwain run their own customs departments, with Fujairah operating the AlFajr system.

Whether a code issued in one emirate is valid in another is not settled by any published rule, either way.No customs department publishes a mutual-recognition provision or its opposite. What the official sources do establish: each emirate runs its own customs department, its own declaration system and its own registration service with its own tariff and its own application form. Author’s assessment: the accurate formulation is that customs codes are issued at emirate level, and a company clearing cargo through the ports of more than one emirate registers in practice with each of those customs departments. One indirect indicator of a common fee basis: Sharjah Customs charges the same AED 100 for registration and AED 25 for renewal as Dubai Customs. Official fee figures for Ajman, Ras Al Khaimah, Fujairah and Umm Al Quwain could not be obtained, and the Dubai numbers must not be extrapolated to them.

A company still choosing its form of presence and its emirate should settle the structure first — that choice is analysed in Mainland vs Free Zone in 2026, and the effect of the licence activity code on banking, VAT and the operating model in UAE Trade Licence Activities 2026.

Mirsal 2: How the Customs Declaration Works in Dubai

Mirsal 2 is Dubai Customs’ electronic customs declaration system, launched on 24 March 2010 in place of Mirsal 1. As at August 2026 it remains the operative declaration system and is accessed through the Dubai Trade portal.

It was built in house: 270,000 person-hours, 120 staff, roughly two years from January 2008, to World Customs Organization standards. Two elements of its architecture carry legal weight: the Risk Assessment Engine, which decides whether customs intervenes, and the electronic signature of transactions by digital certificate.

A declaration type in Mirsal 2 is officially called a Bill of Entry (Declaration). The terminology matters: Appendix B to the Dubai Customs service guide heads its column “Bill Of Entry (Declaration) Types” — so in Dubai practice “declaration” and “Bill of Entry” are synonyms, not two different documents.

Declaration fees, Appendix B to the Dubai Customs service guide (in AED).

Declaration type	Dutiable	Non-dutiable
Import to Local from ROW — from outside the GCC into the local market	70	80
Import to Local from FZ — from a free zone into the local market	70	80
Import to Local from CW — from a customs warehouse into the local market	70	80
Import Statistical Declaration	70	80
Import to CW from ROW — into a customs warehouse	80	80
Import for Re-Export to Local from ROW	100	100
Export from Local to ROW	100	100
Export Statistical Declaration	50	50
Temporary Admission from ROW to Local	100	100
FZ Transit In / FZ Transit Out	80	80
Transfer within a FZ	80	80
Transit (ROW to ROW)	50	15

A single Knowledge and Innovation fee of AED 20 is added to any service costing AED 50 or more. It is not split into an AED 10 “knowledge” fee and an AED 10 “innovation” fee — the 2025 service guide carries it as one line.

An ordinary declaration for dutiable goods imported from outside the GCC into the local market costs AED 70 + AED 20 = AED 90. The only line that falls below the fee threshold is non-dutiable through-transit at AED 15.

Inspection is priced separately. A customer-requested inspection is AED 150, within 2 working hours. An inspection demanded by customs carries no service fee. An inspection seal is AED 20.

There is no published green / yellow / red channel system for commercial cargo in Dubai. The colour channels are official only for passengers, and there are two of them, not three: the Passenger Customs Guide expressly equates passage through the green or red channel with the passenger’s customs declaration. No yellow channel appears anywhere in Dubai Customs’ published material. For cargo, selection runs through Mirsal 2’s Risk Assessment Engine, and declarations clear automatically unless customs sees reason to intervene. Author’s assessment: a source describing “green, yellow and red channels” for Dubai commercial imports is describing a practice Dubai Customs does not publish.

Lodging the declaration and paying the duty are two separate steps. The declaration is filed electronically through Dubai Trade; duty is settled separately by one of five methods: a credit account (CDR) backed by a minimum bank guarantee or deposit of AED 10,000; a Standing Guarantee account with a minimum of AED 25,000; a debit account with a customer-determined deposit; electronic card payment; or cash or cheque (at bureau service points only). Opening a duty account carries no fee, with a processing time of 1 working day for a new account and 5 working days for an amendment.

Supporting documents must be lodged with customs within 14 days of the declaration being processed. Delay costs AED 50 per day, up to a maximum of 90 days.

Three developments in 2025 and 2026 that importers need to know about.

First, the move to a 12-digit tariff. Dubai Customs is rolling out the Integrated Customs Tariff: from roughly 7,809 codes to 13,450, of which 951 are unchanged (zero-padded), 6,518 subdivided and 5,981 newly inserted. The rollout is phased: phase 1, GCC trade, from August 2025; phase 2, free zone and customs warehouse into the local market, from February 2026; phase 3, rest-of-world imports, from August 2026; phase 4, temporary admission and other suspensive procedures, from February 2027. Phase 3 is the flow that hits the ordinary importer, and it switches on in August 2026. Using 12-digit codes outside the permitted phases is itself a breach of Notice No. 10/2025 and may attract penalties. Notice No. 02/2026 of 30 January 2026 nonetheless extended the ability to keep using 8-digit codes “until further notice”.

Second, Al Munasiq. Launched on 20 February 2025, it classifies goods from text, voice or a photograph of the item and returns the duty rate and restriction status. It is a classification aid, not a declaration system: declarations are not lodged through it.

Third, the move to UAE PASS. Customs Notice No. 10/2026 of 23 April 2026, effective 10 May 2026, introduced UAE PASS digital identity for signing customs declarations. Users of cross-border e-commerce platforms and of the B2G channel are expressly excluded. The switch is not compulsory: Article 6 of the notice expressly preserves the existing procedure of signing with a digital certificate on the Dubai Trade portal, in parallel with the option of using UAE PASS. It changes the authentication layer of Mirsal 2, originally built on Dubai Trade digital certificates, but leaves both options open. The parallel move to electronic invoicing and its effect on the documentation chain are analysed in Mandatory Electronic Invoicing in the UAE.

How Much Is the Customs Duty and What Is It Charged On?

The standard rate of customs duty in the UAE is 5 per cent of the CIF value of the goods — the value of the goods plus insurance plus freight.

The rate is set by a federal statute, not by a subordinate instrument. Federal Law No. 19 of 2002 concerning the customs duty payable on goods and materials imported from outside the Customs Union into the GCC states was issued on 25 December 2002, published in Official Gazette No. 391 of 31 December 2002, and came into force on 31 December 2002; its status is active and no amendments are recorded. Article 1 raises the rate from 4 to 5 per cent, applicable from 1 January 2003.

There is a translation trap here that produces the phantom “rate of 4 to 5 per cent” in English-language sources. The official English translation of Article 1 is rendered badly and reads as a range. The Arabic original describes an increase: the rate moves from 4 per cent to 5 per cent. There is no “4–5%” band.

The base is CIF, and that follows from the valuation rules rather than from a separate base provision. The Rules of Implementation of the GCC Common Customs Law require freight, insurance and other related charges to be added to the customs value of the imported goods up to arrival at the port of destination. The practical consequence: a FOB or EXW invoice must be uplifted to the port-of-destination value before the 5 per cent is applied. The UAE government portal puts the same point more briefly: the rate of customs duty is 5 per cent of the value of goods plus Cost Freight Insurance.

Customs valuation follows the WTO Customs Valuation Agreement (Article VII of GATT 1994), transposed into Article 26 of the GCC Common Customs Law and Article 1 of its Rules of Implementation. The methods apply strictly in sequence:

No.	Method
1	Transaction value of the goods being valued
2	Transaction value of identical goods
3	Transaction value of similar goods
4	Deductive value
5	Computed value
6	Fall-back method (reasonable means)

The higher rates.

Tobacco — 100 per cent. The rate is set by Federal Law No. 11 of 1981 imposing federal customs duty on imports of tobacco (issued 14 June 1981, Official Gazette No. 92 of 27 June 1981, active, two amendments). The original Article 2 set 70 per cent. Federal Law No. 2 of 1998 phased it upwards: 80 per cent from 1 July 1998, 90 per cent from 1 July 1999, 100 per cent from 1 July 2000 — with minimum specific duties of AED 20 per kilogram on raw tobacco, AED 60 per kilogram on chopped and manufactured tobacco, AED 200 per kilogram on wrapped cigars and AED 80 per thousand on cigars.

Alcohol — 50 per cent. This figure is published by the UAE government portal, but no federal instrument or tariff line setting 50 per cent could be located — it sits in the GCC Unified Customs Tariff, which could not be obtained as a standalone document. The figure is given with that qualification.

Duty-exempt lines — 53 commodities. Article 2 of Federal Law No. 19 of 2002 exempts the 53 commodities exempted by resolution of the GCC Supreme Council at its 20th session, per the schedule annexed to the law: live animals, fresh meat and fish, vegetables, fruit, cereals, printed books, precious metals, medical vehicles and devices and the like. That exemption operates in addition to the exemptions in the GCC Common Customs Law.

The rates sit in the GCC Unified Customs Tariff (2022 HS edition). Amendments to it were adopted by Cabinet Decision No. 123 of 2023 of 27 November 2023 and implemented in Dubai by Customs Notice No. 01/2024 of 9 January 2024 with effect from 1 January 2024. Article 10 of the GCC Common Customs Law permits duties that are “either ad valorem … or specific … or both”.

Excise is the third charge at the border, and it enters the VAT base. Tobacco products, electronic nicotine delivery systems and sweetened drinks bear excise separately from duty, and the excise amount then forms part of the VAT base under Article 35 of the VAT Law. The practical consequence: tobacco and vape liquids carry four charges in sequence — duty, excise, VAT on the duty-and-excise-inclusive amount, and the declaration fee. The excise model is analysed in UAE Excise Tax 2026, and duty rates and exemptions in Customs Duties in the UAE 2026.

A Comprehensive Economic Partnership Agreement (CEPA) does not change the general rate; it creates a preferential track. Goods that satisfy the agreement’s rules of origin and travel with valid proof of origin enter at the agreement’s scheduled rate — zero from day one for some lines, phased down for others. The domestic mechanism is two-step: first a federal decree ratifying the agreement, then an emirate customs notice bringing it into operation from a stated date. Verified examples: Dubai Customs Notice No. 08/2023 of 31 August 2023 implemented the UAE–Indonesia CEPA from 1 September 2023, citing Federal Decree No. 178 of 2022; Notice No. 01/2026 of 30 January 2026 implemented the UAE–Vietnam CEPA from 3 February 2026, citing Federal Decree No. 135 of 2025.

The UAE publishes no official consolidated register of CEPAs in force, and that should be said plainly.The trade.gov.ae portal lists partners without status or dates; the Ministry of Economy and Tourism’s individual country pages do carry entry-into-force dates. Author’s assessment: for customs purposes the operative date is the one in the emirate’s customs notice, not the signature date and not the ratification date. A preference should be checked against the specific notice, never against an overview page.

Rules and certificates of origin are governed by Federal Law No. 11 of 2019 on the Rules and Certificates of Origin (in force one month after publication, that is, in January 2020). Articles 2 to 3: goods originate where wholly obtained or wholly processed. Article 4: minimal operations do not confer origin. Article 6: the Ministry of Economy issues preferential certificates for national exports, and the chambers of commerce and industry issue non-preferential certificates for re-exported foreign goods. Article 9 lets customs refuse preferential treatment where the validity of origin is in doubt — the key risk provision. Article 14: falsifying origin data carries imprisonment and a fine of AED 100,000 to AED 500,000, doubled for a repeat offence.

When Duty Need Not Be Paid: Suspension, Exemptions and Guarantees

The GCC Common Customs Law separates two fundamentally different constructions: exemption from duty and suspension of its collection. An exemption removes the obligation; a suspension defers it and secures it with a guarantee or a deposit.

Regime	Provision of the GCC Common Customs Law	Substance
Temporary admission	Articles 89 to 94	Entry without collection of customs duties and taxes, against an undertaking to re-export or place the goods in a free zone or warehouse within the prescribed period. Article 90 lists the categories: heavy machinery for projects, goods for processing, exhibition and event items, machinery and equipment entering for repair, containers and packaging entering for filling, animals for grazing, commercial samples, and other cases at the Director-General’s discretion
Transit	Articles 69 to 73	Movement across the territory on prescribed routes through authorised customs offices
Re-export	Article 95	The procedure for exporting previously imported foreign goods
Drawback on re-export	Article 97	Duties and taxes collected on foreign goods are refunded in whole or in part on re-exportation, under the Rules of Imple­menta­tion
Returned goods	Article 105	Goods of national origin or previously re-exported
Passengers’ personal effects and gifts	Article 103	Provided the items are not of a commercial nature
Diplomatic and consular	Articles 99 to 101
Military and internal security forces	Article 102
Charitable societies	Article 104

Security for suspended regimes in Dubai — the minimum amounts.

Instrument	Minimum
Credit account (CDR)	AED 10,000 bank guarantee or cash deposit
Standing Guarantee account	AED 25,000 bank guarantee or deposit
Private customs warehouse	not less than AED 50,000
Public customs warehouse	not less than AED 1,500,000
Virtual Corridor	AED 10,000 virtual guarantee per cargo transfer request

On temporary admission, duties are suspended and covered by a standing guarantee or a deposit equal to the duty that would be payable. On import for re-export, a deposit or guarantee secures the applicable tariff amount in lieu of duty. Through-transit clears against deposits or under guarantees. No deposit applies to an ATA Carnet.

Security on an import-for-re-export can only be reclaimed if the goods were exported within six months.That limit sets the real planning horizon for a distributor working an import–store–re-export model. Proof of export differs by mode: by sea, an exit or entry certificate, a copy of the export declaration or manifest, or a copy of the bill of lading; by air, an exit or entry certificate, a copy of the export declaration, or the airway bill; by land, an exit or entry certificate, a copy of the export declaration or manifest.

A refund claim is filed through the Submit Refund Claim service: AED 50 per declaration plus the AED 20 Knowledge and Innovation fee, AED 70 in total, processed in 5 working days.

This is the point where Dubai Customs’ own publications diverge from one another, and it should be said honestly. The customer guide and Appendix C to the service guide carry different deduction scales for late refund claims: the customer guide gives 15 per cent within 60 days, 30 per cent at 61 to 90 days, 45 per cent at 91 to 120 days and rejection after 120 days; Appendix C gives 15 per cent at 241 to 270 days and 30 per cent at 271 to 300 days. The most plausible explanation is different starting points — expiry of the permitted period in one case and clearance of the declaration in the other. But that is a reconstruction, not a written rule, so no single deduction scale is stated here: the applicable percentage must be checked against the specific declaration.

No limitation period for reclaiming overpaid or wrongly assessed duty — as distinct from release of a deposit — could be found in Dubai Customs’ published services or policies. The commonly repeated “one year” could not be confirmed from a primary source. This analysis does not state one.

The mirror procedure for underpayment is Voluntary Disclosure. The service is free, takes 2 working days, requires a Voluntary Disclosure Form and a Self-Audit Form, must be filed before notification of an inspection or the commencement of a customs audit, and the duty difference is payable within 30 days.

The industrial exemption is where this analysis deliberately stops. Relief from duty on raw materials, machinery and spare parts imported by licensed industrial establishments is administered by the Ministry of Industry and Advanced Technology, which publishes an advisory note on registering items for customs exemption. No federal instrument or Cabinet decision setting the conditions and scope of that relief could be obtained. The scope, the qualifying goods and the legal basis of the industrial exemption are therefore not described here — they should be confirmed directly with the ministry.

The traveller allowance is AED 3,000. Under the Dubai Customs Passenger Customs Guide (version 6, 2025), gifts accompanied by the passenger and worth no more than AED 3,000 are exempt from duty; separately, 200 cigarettes, or 50 cigars, or 500 grams of tobacco; 4 litres of alcohol or 2 cartons of beer (24 cans of 355 ml); and cash and precious metals must be declared above AED 60,000. The AED 3,000 figure does not appear in the text of Article 103 of the GCC Common Customs Law — that article states the exemption without any monetary figure, and the figure sits in the Rules of Implementation, which could not be obtained as a separate document. Article 103 therefore cannot be cited as the source of the amount, and it is not cited that way here.

The AED 1,000 E-Commerce Threshold: What Changed on 3 August 2026

From 3 August 2026, goods and products worth no more than AED 1,000 are exempt from customs duty in Dubai on cross-border e-commerce. The rule is set by Dubai Customs Customs Notice No. 16/2026, issued on 30 July 2026, amending Notice No. 15/2021 of 20 December 2021 on customs procedures for cross-border e-commerce. The notice is signed by the Director-General of Dubai Customs, Dr Abdulla Busenad.

Article 1 of the notice is unambiguous: “Goods and products with a value not exceeding AED 1,000 shall be exempt from customs duties.”

The exemption does not apply to five categories:

•          tobacco and tobacco products;

•          electronic nicotine delivery systems, devices and accessories;

•          liquids containing nicotine;

•          alcoholic beverages;

•          food preparations containing alcohol.

Returns: goods returned through B2C companies are exempt from customs duty where the return occurs within 60 days of the date of their export, provided duty was previously paid.

Article 2 of the notice allocates administrative responsibility — Client Happiness Management registers companies and Legal Affairs resolves disputes over implementation. Article 3 sets the effective date at 03/08/2026.

The history of the threshold matters, because it is usually told wrongly.

Period	Threshold	Instrument
to 31 December 2022	the equivalent of SAR 1,000 — the GCC-level courier threshold	Rules of Imple­menta­tion of the GCC Common Customs Law
1 January to 28 February 2023	AED 300	Dubai Customs Customs Notice No. 05/2022 of 22 June 2022
from 1 March 2023	former threshold reinstated	no published notice of reinstatement exists
from 3 August 2026	AED 1,000, with tobacco, nicotine and alcohol carved out	Customs Notice No. 16/2026

The March 2023 reinstatement was communicated to the market but never published as a customs notice.That should be said plainly: from March 2023 to August 2026 the operative threshold rested on administrative communication rather than on a published instrument. Notice No. 16/2026 closes that gap and gives the threshold a published footing for the first time since 2022.

The direction of travel here runs against the international grain. The debate elsewhere in recent years has been about lowering or abolishing de minimis thresholds for cross-border parcels. Dubai has gone the other way: it raised the threshold and gave it a published instrument, while ring-fencing tobacco, vaping and alcohol. Author’s assessment: this is deliberate industrial policy in favour of a logistics and e-commerce hub, not a technical correction.

Two qualifications, without which the threshold is easily misapplied.

First, Notice No. 16/2026 is an instrument of the Dubai customs department, not a federal act. No official source confirms that the same AED 1,000 threshold applies in Abu Dhabi, Sharjah or the northern emirates, and no federal or supranational instrument raising the threshold could be located. The AED 1,000 figure should be read as the Dubai position, and divergence between emirates treated as a real risk.

Second, and this one costs more: a customs threshold is not a tax threshold. Relief from duty under Notice No. 16/2026 does not of itself relieve import VAT. The two thresholds are set by different instruments and different authorities: duty by the emirate’s customs department, VAT by the VAT Law and the Federal Tax Authority. The practical consequence for a marketplace or an online retailer: a parcel worth AED 900 may clear free of duty and still be within the scope of VAT.

The licensing mechanics of online trading and the logistics side of the model are covered in UAE E-Commerce Licence 2026 and E-Commerce in the UAE: How to Launch a Business in 2026.

Two further temporary measures introduced in 2026 bear directly on how cargo is routed. Dubai Customs Customs Notices No. 04/2026 of 14 March 2026 and No. 06/2026 of 4 April 2026 activated a “Green Corridor” with Oman for sea and air cargo diverted overland through the Hatta and Al Wajajah crossings: carriage in sealed bonded trucks, with the cash deposit waived and replaced by a letter of guarantee. Notice No. 06/2026 is expressly temporary, “until further notice”, and responds to disruptions to sea and air connectivity to GCC destinations. Customs Notice No. 13/2026 of 24 June 2026 imposed a temporary ban on exporting industrial-use waste — ferrous, copper and aluminium scrap under listed HS codes — for four months from 10 June to 8 October 2026, renewing automatically unless cancelled by notice. Note the retroactivity: the notice is dated 24 June while the ban runs from 10 June 2026.

Import VAT: What the 5 Per Cent Is Charged On

VAT on the import of goods into the UAE is charged at 5 per cent of the customs value increased by insurance, freight, customs duty and excise tax. The VAT itself is not included in its own base.

Article 35 of the VAT Law states the base verbatim: “The Import value of Goods consists of: 1. The customs value pursuant to Customs Legislation, including the value of insurance, freight and any customs fees and Excise Tax paid on the Import of the Goods. Tax shall not be included in the value of the supply. 2. If it is not possible to determine the value pursuant to Clause 1 of this Article, the value shall be determined based on alternate valuation rules stated in the applicable Customs Legislation.”

This is the 2017 provision and it has never been amended. The practical consequence fits in one sentence: 5 per cent VAT sits on top of 5 per cent duty, and on excisable goods it sits on top of duty and excise together.

Element	In the import VAT base?
Invoice value of the goods	yes
Freight to the port of destination	yes
Insurance	yes
Customs duty	yes
Excise tax	yes
The customs declaration fee	not named in Article 35
The VAT itself	no — expressly excluded

A numerical illustration on a simple case. Goods invoiced FOB at USD 100,000, with freight and insurance of USD 5,000. The CIF customs value is USD 105,000. Duty at 5 per cent is USD 5,250. The VAT base is USD 110,250 and VAT at 5 per cent is USD 5,512.50. Had VAT been computed on CIF without the duty, it would have been USD 5,250 — a difference of USD 262.50 on a single shipment, and a material figure across an annual volume. This is not optimisation but the arithmetic of Article 35: an error in the base is an underpayment, and underpaid import VAT carries its own line in the penalties table.

The Article 1 definitions without which the import provisions read wrongly.

•          Import — “The arrival of Goods from abroad into the territory of the State or receipt of Services from outside the State”. Note that for services the import is the receipt of the service, not the crossing of a border — there is no customs event at all.

•          Concerned Goods — “Goods that have been imported, and would not be exempt if supplied in the State”.

•          Concerned Services — “Services that have been imported, where the place of supply is considered to be in the State, and would not be exempt if supplied in the State”.

•          Importer — “With respect to importing Goods, it is the Person whose name appears for customs clearance purposes as the importer of the Goods on the date of Import. With respect to Services, it is the Recipient of these Services”.

•          Input Tax — “Tax paid by a Person or due from him when Goods or Services are supplied to him, or when conducting an Import”.

•          Customs Legislation — “Federal and local legislation that regulate customs in the State”.

The definition of Importer is the provision that settles arguments about whose import it is. For VAT purposes the importer is the person whose name appears as the importer for customs clearance purposes on the date of import. Not the owner of the goods, not the party paying the invoice, not the consignee on the bill of lading — the party shown as importer on the declaration. Author’s assessment: this is the one provision to remember whenever a freight forwarder or broker clears the cargo, because it determines in whose VAT return the import VAT arises and therefore who has to deal with recovering it.

The import rate is the same as the domestic supply rate. Article 3 of the VAT Law: “Without prejudice to the provisions of Title Six of this Decree-Law, a standard rate of 5% Tax shall be imposed on any supply or Import pursuant to Article 2 of this Decree-Law on the value of the supply or Import specified in accordance with the provisions of this Decree-Law.” There is no separate “import rate” in the UAE.

The general mechanics of VAT — registration, returns and deadlines — are covered in UAE VAT: The Complete Business Guide 2026.

How Not to Pay VAT at the Border: Reverse Charge and the TRN–Customs Number Link

A VAT-registered importer does not pay import VAT at the border but accounts for it in its own return under the reverse charge mechanism — provided the four conditions in Article 48 of the Executive Regulation are met, one of which is giving the Federal Tax Authority its own customs registration number.

The basis is Article 48(1) of the VAT Law. In the wording in force from 1 January 2026: “If the Taxable Person imports Concerned Goods or Concerned Services for the purposes of his Business, then he shall be treated as making a Taxable Supply to himself, and shall be responsible for accounting for the Due Tax on that Supply and complying with all other Tax obligations arising, with the exception of issuing a Tax Invoice to himself.”

The 2026 change: no more self-invoicing. The previous wording required the taxpayer to issue a tax invoice to itself when applying the reverse charge. Federal Decree-Law No. 16 of 2025, in force from 1 January 2026, removed that requirement. The Federal Tax Authority had already reached the same result administratively through public clarification VATP044 of 26 May 2025, which allowed recovery without a self-invoice where the overseas supplier’s invoice was retained. From 2026 the relief sits in the statute itself.

The four conditions in Article 48(1) of the Executive Regulation, verbatim:

No.	Condition
a	“At the time of Import, the Taxable Person can demonstrate that they are registered for Tax”
b	“The Taxable Person has sufficient details for the Authority to verify the Import and the Tax which shall be due on the Import and is able to provide these as required”
c	“The Taxable Person has provided the Authority with its own Customs registration number issued by the competent Customs Department for that Import, such Customs Departments to verify the Import subject to the rules set by the Authority”
d	“The Taxable Person has cooperated with, and complied with any rules imposed by, the Authority in respect of the Import”

Clause 2 of the same article closes the construction: “Where the conditions mentioned in Clause 1 of this Article are not met, the Taxable Person shall account for Tax in respect of the Import in accordance with Clause 1 of Article 50 of this Decision.” And Article 50(1) requires the tax to be paid before the goods may be released.

Sub-paragraph (c) is the legal hook for the TRN–customs number link, and the whole construction hangs on it. If the customs registration number has not been given to the tax authority, the condition fails, Article 48(2) bites, and the importer lands in Article 50(1) — cash at the border. Author’s assessment: this is not a lost deduction but a cash-flow gap — yet on regular import volumes it becomes permanently frozen working capital, and it is discovered when the cargo is already at the port.

How the link is made. It is made on the Federal Tax Authority’s side, not on the customs side: in EmaraTax through a registration amendment — log in, the Taxable Person tile, Actions on the VAT tile, complete the “first amendment”, after which an Edit option exposes the ability to link the customs registration number to the TRN. The tax authority separately warns that some registration details — trade licence, business activities — may have become outdated, which is why the “first amendment” must be completed first.

There is an internal inconsistency between two Federal Tax Authority pages here, and it is worth knowing about. The VAT records amendment service page states that customs registration information is among the fields that do not require approval and can be edited directly; the EmaraTax FAQ describes the process as an amendment that goes through approval. The indicative processing time for amendments requiring approval is 20 working days. The practical consequence: budget working weeks rather than hours for the linkage, and complete it before the first shipment, not after.

What happens when the conditions are met — Article 48(4) of the Executive Regulation. The taxable person must account for tax on the value of the Concerned Goods or Concerned Services at the rate that would apply to a domestic supply, and declare and pay the tax in the return for the tax period in which the date of supply fell.

What must be retained — Article 48(5) of the Executive Regulation: the supplier’s invoice showing the details and the consideration paid, and for goods, “a statement from the relevant Customs Department showing details and the value of the Concerned Goods”. That is the customs document on which the deduction rests.

Imported services run under the same article but on different mechanics. The conditions in Article 48(1) of the Executive Regulation are expressed for goods only — registration status and the customs number have no application to services, because there is no customs event. Clause 3 of the same article extends the regime further than is generally appreciated: where a UAE-resident taxable person receives a supply with a UAE place of supply from a non-resident supplier who does not charge tax, the supply is treated as Concerned Goods or Concerned Services and falls within Article 48(1) of the Law. VATP044 confirms that the recipient may recover the tax even without issuing a tax invoice to itself, provided it retains the overseas supplier’s invoice.

> There is no general deferral of import VAT in the UAE, and that should be said plainly. Article 49(2) of the Executive Regulation permits deferral only with the Federal Tax Authority’s express approval and only in the Article 48(2) case — where the final destination of the goods on entry is another GCC Implementing State. The de facto “deferral” for an ordinary importer is the reverse charge: cash neutrality is achieved by declaration, not by postponed accounting in the European sense.

What to Do When the Importer Is Not VAT-Registered

An importer that is not registered for VAT pays the import tax to the Federal Tax Authority before the goods are released. The provision is Article 50(1) of the Executive Regulation, and customs departments are required to confirm the tax has been settled before releasing the cargo.

Article 50 of the Executive Regulation, “Special Rules of Import”, has eight clauses and operates as a self-contained code. Unlike Articles 47 and 48, this article has been amended: footnote 26 to the consolidated Regulation states expressly “Article amended as per Cabinet Decision No. 100 of 2024”, so the current wording has applied since 15 November 2024. Articles 47 and 48 carry no amendment footnote and stand as enacted in 2017.

The amendment to Article 50 is not explained by any Federal Tax Authority clarification, and that is worth knowing. Public clarification VATP040, devoted specifically to the amendments made by Cabinet Decision No. 100 of 2024, does not address Article 50. Author’s assessment: practice under the new wording is still forming without official commentary, and where the agency arrangement is finely balanced the position is worth confirming with the authority on the specific facts.

Clause	Content
1	Where Concerned Goods are imported by an unregistered person or by a taxable person who fails the conditions of Article 48(1), the tax is paid to the authority before the goods may be released
2	“The Customs Departments shall cooperate with the Authority to ensure that Payable Tax on Import has been settled before releasing of Goods”
3	Payment is made by the method specified by the authority
4	Where an unregistered person imports through an agent who is VAT-registered in the UAE and acts on its behalf, the agent is responsible for paying the tax
5	The tax is reported and paid through the agent’s return as though the agent were itself the importer
6	An agent who has paid tax on behalf of another person may not recover it as input tax
7	The agent issues the person a statement containing at least: the agent’s name, address and TRN; the date of issue; the date of import; a description of the imported goods; and the amount of tax the agent paid to the authority
8	That statement is treated as a tax invoice for the documentation requirement in Article 55(1)(a) of the Law

The pairing of clauses 6 and 8 is the most under-appreciated construction in the whole import chapter.The agent pays but cannot recover; the recovery belongs to the owner of the goods, through the agent’s statement operating as a tax invoice. Author’s assessment: a forwarder who puts itself on the declaration as importer “to be safe” and then recovers the import VAT in its own return breaches clause 6 directly. And an owner who never obtains the clause 7 statement is left without the document its own recovery depends on.

The procedure for an unregistered importer in practice. The customs declaration is lodged normally and moves into a pending-tax-payment status; the importer registers for an account on the Federal Tax Authority’s portal and completes the VAT301 import declaration form, in which the details — HS code, import value, customs duty, CIF value — are pulled automatically from the customs declaration; payment is then selected and made. Import VAT is computed on the value of the goods inclusive of customs duty and excise tax.

A qualification about the currency of that procedure, made honestly. The most recent published Federal Tax Authority import declaration guide is version 6.0 of January 2022 — before the migration to EmaraTax. It could not be confirmed from a current tax authority page that the VAT301 form exists in EmaraTax in 2026 in that form: the relevant service page is closed to automated access. This analysis describes the mechanism set by the Executive Regulation and does not assert that the form’s interface is unchanged. The current EmaraTax journey should be checked in the portal itself.

The e-Guarantee — security instead of payment. In the scenarios where goods are not released into free circulation — movements between Designated Zones and imports under duty suspension — the importer obtains an electronic guarantee from its bank for the amount of VAT due and enters its reference in place of payment. The legal basis is not a dedicated “e-Guarantee” instrument but two provisions of the Executive Regulation:

•          Article 47(1)(a) — goods under customs duty suspension are not treated as imported, “subject to providing a financial guarantee or a cash deposit equal to the value of the Due Tax if and when requested by the Authority”;

•          Article 51(4) — “Where Goods are moved between Designated Zones, the Authority may require the owner of the Goods to provide a financial guarantee for the payment of Tax”.

The term “eGuarantee” appears nowhere in the VAT Law, the Executive Regulation or the Designated Zones guide. It is the Federal Tax Authority’s operational product name for the financial guarantee under Article 51(4) and Article 47(1)(a). It cannot be cited as statutory language; the provisions themselves must be. The VAT702 guide, referenced by the tax authority’s own guide for cancelling an electronic guarantee, could not be obtained, and its contents are not described here.

A separate category exists on the tax authority’s side: customs brokers. The Federal Tax Authority registers customs clearance companies and issues them special reference numbers distinct from an ordinary TRN: TINCO for VAT and TINCE for excise. The purpose is to let an agent clear goods on behalf of unregistered persons. The requirements: a trade licence expressly showing customs clearance activity; the company’s own VAT registration or membership of a tax group; a financial guarantee from a UAE bank in an amount set by the tax authority; and a services agreement with the authority. The service is free and processed within 20 working days. Where importing is arranged through a local representative on a contractual basis, the commercial agency regime adds a separate layer of risk — analysed in UAE Commercial Agency Law 2026.

Which Imports Bear No VAT at All

Article 47 of the Executive Regulation separates two constructions: imports that are not treated as imports at all, and imports on which no tax is due because the goods carry a customs exemption. These are different grounds and must not be conflated.

Article 47(1) — goods not treated as imported into the UAE:

•          sub-paragraph (a) — goods under customs duty suspension under the GCC Common Customs Law, subject to providing a financial guarantee or a cash deposit equal to the value of the tax due, if and when requested by the authority, in four cases: 1) temporary admission; 2) goods placed in a customs warehouse; 3) goods in transit; 4) imported goods intended to be re-exported by the same person;

•          sub-paragraph (b) — goods imported into a Designated Zone from a place outside the UAE.

Article 47(2) — imports on which no tax is due because the goods are exempt from customs duty under the GCC Common Customs Law:

•          (a) goods imported by the military forces and internal security forces;

•          (b) personal effects and gifts accompanied by travellers;

•          (c) used personal effects and household items transported by UAE nationals living abroad on return, or by expatriates moving to live in the UAE for the first time;

•          (d) returned goods.

Article 47(3) removes the tax from an import made through another Implementing State where the authority establishes that tax is due on the supply or transfer of the goods in that other state. Article 47(4) empowers the authority to specify procedures for importers and customs departments.

There is no diplomatic exemption in Article 47, and this is regularly stated wrongly. The clause 2 list is closed: military and internal security forces, travellers’ personal effects and gifts, used household items of returning nationals and first-time expatriates, and returned goods. VAT relief for foreign governments and diplomatic missions runs through a separate refund scheme, not through Article 47.

Sub-paragraph (a) of clause 1 is a conditional relief, not an unconditional one. Goods are not treated as imported “subject to providing a financial guarantee or a cash deposit” — the relief is conditioned on security the authority may require. The practical consequence: temporary admission, transit, customs warehousing and import-for-re-export defer duty and VAT together, but each circuit requires its own security, because customs security is lodged with the emirate’s customs department and tax security with the Federal Tax Authority.

The symmetry between the customs and tax circuits at this point is deliberate and useful.

Situation	Customs circuit	Tax circuit
Temporary admission	Articles 89 to 94 of the GCC Common Customs Law — suspension under guarantee	Article 47(1)(a)(1) of the Executive Regulation — not treated as an import, under guarantee
Customs warehouse	warehousing regime	Article 47(1)(a)(2)
Transit	Articles 69 to 73	Article 47(1)(a)(3)
Import for re-export	deposit or guarantee in lieu of duty, refundable on export within 6 months	Article 47(1)(a)(4)
Travellers’ personal effects and gifts	Article 103 of the GCC Common Customs Law	Article 47(2)(b)
Returned goods	Article 105	Article 47(2)(d)
Import into a Designated Zone	entry into the zone	Article 47(1)(b)

> Author’s assessment: this table is the most under-used import planning tool in the UAE. Every suspension regime on the customs side has a mirror provision on the tax side. The practical consequence: choosing a customs regime is simultaneously a decision about when the VAT obligation arises, and it should be taken as one decision, not by two different people in two different departments.

Designated Zones: the Full List and How It Was Built

A Designated Zone is a zone expressly named in Cabinet Decision No. 59 of 2017 (as amended) that also meets, in fact, the conditions in Article 51(1) of the Executive Regulation. Such a zone is treated as being outside the UAE — but for goods only.

The statutory basis is Article 50 of the VAT Law, and it is a single sentence: “A ‘Designated Zone’ that meets the conditions specified in the Executive Regulation of this Decree-Law shall be treated as being outside the State.” Article 50 has never been amended.

The adjacent provisions. Article 51: “Goods may be transferred from one Designated Zone to another Designated Zone without any Tax becoming due”, with the Executive Regulation specifying the procedures and conditions of transfer and the mechanism for keeping, storing and processing goods. Article 52: as an exception to Article 50, the Executive Regulation specifies the conditions under which business conducted within a Designated Zone is regarded as conducted in the UAE.

The amendment chain for the list runs to six instruments, and nothing has changed since 2021. The Federal Tax Authority’s consolidated publication states it verbatim: “Based on Cabinet Decision No. 59 of 2017 on Designated Zones for the purposes of the Federal Decree-Law No. 8 of 2017 on Value Added Tax (effective 1 January 2018); and decisions amending thereof: Cabinet Decision No. 35 of 2018 effective 18 June 2018; Cabinet Decision No. 43 of 2019 effective 4 July 2019; Cabinet Decision No. 34 of 2021 effective 4 April 2021; Cabinet Decision No. 63 of 2021 effective 1 July 2021; Cabinet Decision No. 81 of 2021 effective 12 September 2021.”

The list in force as at August 2026 runs to 24 zones. Twenty-seven zones have been listed at some point; three have been removed.

Emirate	Zone	In force from	Removed
Abu Dhabi	Free Trade Zone of Khalifa Port	01.01.2018	—
Abu Dhabi	Abu Dhabi Airport Free Zone	01.01.2018	—
Abu Dhabi	Khalifa Industrial Zone (KIZAD)	01.01.2018	—
Abu Dhabi	Al Ain International Airport Free Zone	18.06.2018	—
Abu Dhabi	Al Butain International Airport Free Zone	18.06.2018	—
Dubai	Jebel Ali Free Zone (North-South)	01.01.2018	—
Dubai	Dubai Cars and Automotive Zone (DUCAMZ)	01.01.2018	—
Dubai	DAFZA Industrial Park Free Zone — Al Qusais	01.01.2018	—
Dubai	Dubai Aviation City	01.01.2018	—
Dubai	Dubai Airport Free Zone	01.01.2018	—
Dubai	International Humanitarian City — Jebel Ali	18.06.2018	—
Dubai	Dubai CommerCity	01.01.2021	—
Dubai	Dubai Textile City	01.01.2018	04.04.2021
Dubai	Free Zone Area in Al Quoz	01.01.2018	01.07.2021
Sharjah	Hamriyah Free Zone	01.01.2018	—
Sharjah	Sharjah Airport International Free Zone	01.01.2018	—
Ajman	Ajman Free Zone	01.01.2018	—
Umm Al Quwain	Umm Al Quwain Free Trade Zone in Ahmed Bin Rashid Port	01.01.2018	—
Umm Al Quwain	Umm Al Quwain Free Trade Zone on Sheikh Mohammed Bin Zayed Road	01.01.2018	—
Ras Al Khaimah	RAK Port Free Zone	01.01.2018	—
Ras Al Khaimah	RAK Maritime City Free Zone	01.01.2018	—
Ras Al Khaimah	Al Hamra Industrial Zone — Free Zone	04.07.2019	—
Ras Al Khaimah	Al Ghail Industrial Zone — Free Zone	04.07.2019	—
Ras Al Khaimah	Al Hulaila Industrial Zone — Free Zone	04.07.2019	—
Ras Al Khaimah	RAK Airport Free Zone	01.01.2018	04.07.2019
Fujairah	Fujairah Free Zone	01.01.2018	—
Fujairah	FOIZ (Fujairah Oil Industry Zone)	01.01.2018	—

What each amendment did.

Instrument	In force from	Change
Cabinet Decision No. 59 of 2017	01.01.2018	The original list — 20 zones
Cabinet Decision No. 35 of 2018	18.06.2018	Added three: Al Ain International Airport Free Zone, Al Butain International Airport Free Zone, International Humanitarian City — Jebel Ali
Cabinet Decision No. 43 of 2019	04.07.2019	Removed RAK Airport Free Zone; added three Ras Al Khaimah industrial zones: Al Hamra, Al Ghail, Al Hulaila
Cabinet Decision No. 34 of 2021	04.04.2021	Removed Dubai Textile City
Cabinet Decision No. 63 of 2021	01.07.2021	Removed Free Zone Area in Al Quoz
Cabinet Decision No. 81 of 2021	12.09.2021	No zone in the list carries the date 12.09.2021; Dubai CommerCity was added with retroactive effect from 01.01.2021 by one of the three 2021 decisions — the specific attribution could not be confirmed from the texts

The zones that are not on the list are what most often surprises people. DMCC — no. DIFC — no. Dubai Silicon Oasis — no. Dubai Media City, d3 and DWTC — no. Masdar City — no. Only five Abu Dhabi zones appear: Khalifa Port, Abu Dhabi Airport, KIZAD, Al Ain International Airport and Al Butain International Airport. RAKEZ is not named as a single entity: three industrial zones it administers are listed individually, and RAK Airport Free Zone has been off the list since 4 July 2019. The formula “RAKEZ = Designated Zone” is wrong — status is checked zone by zone.

A qualification about the source, made honestly. The gazetted texts of Cabinet Decision No. 59 of 2017 and of all five amending decisions are absent from the accessible official resources — they appear neither on the legislation portal, nor on the Ministry of Finance site, nor in the Federal Tax Authority’s legislation library. Exactly one official document exists: the consolidated list published by the Federal Tax Authority as at 21 September 2021, which remains current in August 2026. The zone names and dates in the table above are taken from it. It is an official consolidation, not the text of the decision itself, and the names given should not be presented as quotations from Cabinet Decision No. 59. Note separately that the English names in the Federal Tax Authority’s own table diverge in places from the familiar 2017 zone names: the list carries “DAFZA Industrial Park Free Zone — Al Qusais” and “RAK Port Free Zone” rather than “Free Zone Area in Al Qusais” and “RAK Free Trade Zone”. The table above uses the names as they appear in the current publication.

A worked example of a zone carrying Designated Zone status is set out in JAFZA in 2026: the Jebel Ali Free Zone, Designated Zone Status, Offshore Companies and the Port, and the airport-zone profile in DAFZA: the free zone at Dubai Airport.

How a Designated Zone Works: Four Requirements, Consumption, Transfers and Services

Being on the list is necessary but not sufficient. Article 51(1) of the Executive Regulation sets three conditions, and a zone that fails them is treated as being inside the UAE.

Article 51(1), verbatim: “Any Designated Zone specified by a decision of the Cabinet shall be treated as being outside the State and outside the Implementing States, subject to the following conditions: a. The Designated Zone is a specific fenced geographic area and has security measures and Customs controls in place to monitor entry and exit of individuals and movement of goods to and from the area. b. The Designated Zone shall have internal procedures regarding the method of keeping, storing and processing of Goods therein. c. The operator of the Designated Zone complies with the procedures set by the Authority.”

Article 51(2): where a zone changes the manner in which it operates or breaches any of the conditions on which it was specified as a Designated Zone by Cabinet decision, the zone is treated as if inside the UAE.

The Regulation states three lettered conditions; the Federal Tax Authority’s Designated Zones guide states four, splitting sub-paragraph (a) in two. Hence the familiar formulation: a specific fenced geographic area; security measures and customs controls monitoring the movement of people and goods; internal procedures for keeping, storing and processing goods; and the operator’s compliance with the authority’s procedures. The guide adds a critical qualification: where a zone has areas that meet the requirements and areas that do not, it is treated as outside the UAE only to the extent that the requirements are met.

Services inside a Designated Zone are taxed as if in the UAE. Article 51(6): “The place of supply of any Services is considered to be inside the State if the place of supply is in the Designated Zone.” The tax authority’s guide spells out the consequence: this override of the normal place-of-supply rules means that in all circumstances the place of supply of services in a Designated Zone reverts to the UAE, and such supplies are taxed under the general rules — most services at the standard rate, with export of services to a person outside the Implementing States potentially zero-rated.

Article 51(8) extends the same treatment to water and any form of energy: their place of supply in a Designated Zone is considered to be in the UAE. Article 51(10): any person established, registered or resident in a Designated Zone is deemed to have a place of residence in the UAE for the purposes of the Law.

Article 51(7) is a narrow carve-out from clause 6, added by Cabinet Decision No. 88 of 2021: shipping and delivery directly connected with goods whose place of supply is outside the UAE under sub-paragraphs (b) and (c) of clause 5, where all of the following hold: the same supplier as the goods; the supplier is a non-resident not registered for VAT; the goods are sold through an electronic sales platform; and the platform owner is not the supplier.

Consumption of goods in a Designated Zone is governed by two distinct provisions, and they must not be merged.

Article 51(5) is the place-of-supply rule for goods supplied to be consumed. The place of supply is in the UAE exceptin three cases: (a) the purpose was to incorporate the goods into, attach them to, make them part of, or use them in producing another good in the same Designated Zone, and that other good is not consumed; (b) the goods were delivered to a place outside the UAE and the supplier retains commercial or official evidence of that, plus customs evidence that the goods left the zone; (c) the goods were moved from the zone into the UAE and the supplier retains official evidence that VAT was applied on that import.

Article 51(9) is the deemed-import rule. Goods in a Designated Zone on which the owner has not paid tax are treated as imported into the UAE if: (a) the goods are consumed by the owner, unless they are incorporated into, attached to, form part of, or are used in producing another good located in a Designated Zone that is not itself consumed; or (b) there is a shortage in the goods.

“Consumption” is read broadly, and resale is not consumption. The Federal Tax Authority’s guide defines consumed “broadly as including any utilisation, application, employment, deployment or exploitation of the goods”, and immediately qualifies it: the resale of purchased goods is not treated as consumption. The practical consequence: stock held in the zone for resale stays outside the scope of VAT; the same stock taken off the shelf for the company’s own use becomes a deemed import. A stocktake shortage produces the same result — a deemed import under Article 51(9)(b).

Transfers between Designated Zones — Article 51(3) and (4). A transfer is not subject to tax where both conditions are met: (a) the goods, or part of them, are not released and are not in any way used or altered during the transfer between the zones; and (b) the transfer is undertaken in accordance with the rules for customs suspension under the GCC Common Customs Law. Clause 4: where goods move between zones, the authority may require the owner to provide a financial guarantee for the payment of tax that may become due if the conditions for movement are not met.

Sub-paragraph (b) of clause 3 is where the tax and customs circuits are stitched together hard. Relief from VAT on an inter-zone movement is conditioned on compliance with the customs suspension rules. Author’s assessment: a movement processed as an “internal transfer” without a customs suspension procedure does not on its face satisfy sub-paragraph (b), and the tax neutrality of that movement is not secured — regardless of both zones being on the list.

The current guide and clarification on Designated Zones. Guide VATGDZ1 is dated August 2018 and remains published. Public clarification VATP027 — “Goods supplied in a Designated Zone, and connected shipping or delivery services” — reflects the amendments effective 30 October 2021.

> VATGDZ1 is older than the current text of Article 51, and that must be borne in mind when reading it. Issued in August 2018, it entirely predates Cabinet Decision No. 88 of 2021, which rewrote clauses 5 to 10 of Article 51. Where VATGDZ1 diverges from the current Regulation, the Regulation and VATP027 govern. Author’s assessment: an eight-year-old guide left in force alongside amended law is a genuine weak point, and it cannot be relied on as a sole source.

Designated Zone, Free Zone and Qualifying Free Zone Person — Three Distinct Concepts

A Designated Zone for VAT and a Free Zone for corporate tax are two different lists with two different consequences. Holding one status does not confer the other.

The three concepts most often merged.

Concept	Instrument	What it confers
Free Zone (in the everyday sense)	The founding instrument of the specific zone — an emirate law or decree	Licensing, 100 per cent foreign ownership, infra­stru­cture. Of itself it confers neither a tax nor a customs status
Designated Zone(VAT)	Cabinet Decision No. 59 of 2017 as amended, plus actual compliance with Article 51(1) of the Executive Regulation	The zone is treated as outside the UAE — for goods only. Services inside the zone are taxed as if in the UAE
Qualifying Free Zone Person(corporate tax)	Federal Decree-Law No. 47 of 2022 + Cabinet Decision No. 100 of 2023 + Ministerial Decision No. 229 of 2025	A 0 per cent corporate tax rate on Qualifying Income, subject to conditions

The current corporate tax instruments — and two links in this chain are regularly cited in superseded form.

•          Cabinet Decision No. 100 of 2023 on determining Qualifying Income for the Qualifying Free Zone Person was issued on 25 October 2023 and takes effect from 1 June 2023. Article 10 expressly repeals Cabinet Decision No. 55 of 2023. Citing Decision No. 55 in 2026 is citing a repealed instrument.

•          Ministerial Decision No. 229 of 2025 on Qualifying Activities and Excluded Activities was issued on 28 August 2025 and takes effect from 1 June 2023. Article 6 expressly repeals Ministerial Decision No. 265 of 2023, which had itself replaced Ministerial Decision No. 139 of 2023.

•          Federal Tax Authority Decision No. 6 of 2026 on additional procedures for Qualifying Free Zone Person compliance was issued on 2 June 2026 and published on 14 July 2026. It is the most recent QFZP instrument.

The single hard link between the two regimes is distribution. Cabinet Decision No. 100 of 2023 defines a Designated Zone by cross-reference to the VAT Law: “A designated zone according to what is stated in Federal Decree-Law No. (8) of 2017 on Value Added Tax, and which has been included as a Free Zone in accordance with the Corporate Tax Law”. And Article 2 of Ministerial Decision No. 229 of 2025 lists among the Qualifying Activities “Distribution of goods or materials in or from a Designated Zone” — conditioned on goods entering the UAE being imported through the Designated Zone, and supplies going to buyers who resell or process them, or to public benefit entities.

Designated Zone status is a precondition for exactly one qualifying activity — distribution — and for nothing else. The Federal Tax Authority’s free zone guide states it in terms: certain activities are performed within the prescribed geographical areas of a free zone “or a Designated Zone for distribution activities”, and taxpayers are invited to check with their own zone authority whether they operate in a Free Zone or a Designated Zone for corporate tax purposes.

A practical matrix that removes most of the confusion.

Zone	Designated Zone (VAT)	Free Zone for corporate tax
JAFZA	yes	yes
DAFZA	yes	yes
KIZAD	yes	yes
Hamriyah, SAIF, Ajman Free Zone, Fujairah FZ, FOIZ	yes	yes
DMCC	no	yes
DIFC	no	yes
Dubai Silicon Oasis / IFZA	no	yes
Dubai Media City, d3, DWTC	no	yes
Masdar City	no	yes

The asymmetry runs both ways, and both directions are unpleasant. DIFC and DMCC are free zones whose registered companies may claim the 0 per cent corporate tax rate, but they are not Designated Zones: goods brought into DMCC have been imported into the UAE, and import VAT arises on entry.The reverse: a zone that does hold Designated Zone status gets nothing on the corporate tax side if its member fails the QFZP conditions. Author’s assessment: the warehousing model is chosen from the Cabinet Decision No. 59 list, not from a zone’s marketing material; the tax model is chosen from Ministerial Decision No. 229 of 2025. Bringing those two decisions together into one choice of site is the most valuable thing that can be done at the structuring stage.

The Cabinet has not published a consolidated list of free zones for corporate tax purposes. The Federal Tax Authority’s guide expressly invites taxpayers to seek confirmation from their own zone authority. That is not a research gap but a gap in the regime itself: the VAT list is published and markedly shorter, while the corporate tax list is not published at all.

The conditions for the zero rate and the usual ways of losing it are analysed in Qualifying Free Zone Person Regime in 2026 and How companies in Free Zones lose 0% corporate tax in the UAE in 2026.

How to Recover Import VAT, and in Which Period

Import VAT is deducted in the return for the first tax period in which the conditions of Article 55(1) of the VAT Law are all satisfied, and if that period is missed, in the return for the next tax period. Two periods, and no more.

Article 54 defines what is recoverable at all. Clause 1: input tax paid on goods and services used or intended to be used for taxable supplies; for supplies made outside the UAE that would have been taxable had they been made in the UAE; and for supplies specified in the Executive Regulation made outside the UAE that would have been exempt inside it.

Article 54(4) is a trap that is almost never written about. Tax paid under Article 48(2) of the Law — on the import of goods whose final destination is another Implementing State — is not recoverable at all. Not carried forward, not refundable on application: not recoverable.

The Article 55(1) conditions — the deduction is available in the first tax period in which the following are met.

Condition	Content
(a)(1) — domestic supplies	The taxable person receives and retains the tax invoice showing the details of the supply, or another document under Article 65(3)
(a)(2) — imported goods	The taxable person imports the goods and receives and retains invoices and import documents in accordance with the Law and its Executive Regulation, in relation to the import on which input tax was paid or declared
(a)(3) — imported services	The taxable person imports the services and receives and retains invoices in relation to the import on which input tax was declared
(b)	The taxable person pays the consideration or part of it, as specified in the Executive Regulation
(c)	The taxable person retains the tax invoice in accordance with the Electronic Invoicing System, where it is required to be issued or has been issued as an electronic invoice
(d)	Any other condition prescribed by the Cabinet on the Minister’s proposal

Article 55(2): where a taxable person entitled to recover input tax fails to do so in the period in which the conditions were satisfied, it may include the recoverable input tax in the return for the subsequent tax period.

Sub-paragraph (a)(2) is drafted more precisely than it looks, and the precision is the whole point. It requires “invoices and Import documents” — the supplier’s invoice plus the customs document, not one or the other. And it says “paid or declared”, which is exactly what makes reverse-charged import VAT recoverable without a single payment to the tax authority. The specific customs document is named in Article 48(5)(b) of the Executive Regulation: “a statement from the relevant Customs Department showing details and the value of the Concerned Goods”.

Where an agent cleared the cargo, the agent’s statement becomes the document. Article 50(8) of the Executive Regulation treats the agent’s statement as a tax invoice for the purposes of Article 55(1)(a) specifically.

How import VAT reaches the return — Box 6 and Box 7.

Box 6, “Goods imported into the UAE”, is auto-populated from imports declared under the taxable person’s customs registration number, with the VAT column computed by applying 5 per cent to the net value. The taxable person must reconcile those values against its own import declarations for the period.

Box 7, “Adjustments to goods imported into the UAE”, is the field for cases where the pre-populated Box 6 data is incomplete or incorrect. The typical cases: imports missing from Box 6; goods bearing a rate other than 5 per cent; imports made by an agent on behalf of an unregistered person. The responsibility for identifying and making the adjustments is placed expressly on the taxable person.

Public clarification VATP012 sets out the mechanics for the commonest configuration — where a forwarder clears the cargo. The agent shown as importer of record makes a negative adjustment in Box 7, nullifying the amount pre-populated in Box 6; the owner makes a positive adjustment in Box 7, bringing in the value of the goods imported on its behalf, and then recovers the tax in Box 10. The parties must agree the adjustments in writing and retain that agreement alongside the customs documentation. The alternative route is the agent’s Article 50(7) statement, which the owner uses as a tax invoice and recovers through Box 9.

Import VAT paid before registration — Article 56. A registrant may recover input tax incurred before registration in the return for the first tax period following registration, including on the import of goods before the date of registration, provided those goods were used for supplies giving the right of recovery after registration. The exclusions in Article 56(2): goods and services received for purposes other than taxable supplies; the part of capital assets depreciated before registration; services received more than 5 years before the date of registration; and goods moved to another Implementing State before registration.

The five-year bar in Article 56(2) is drafted for services, not goods — but the window is tighter than usual all the same. For goods imported before registration, the deduction is claimed in the first return after registration, a single opportunity, whereas the ordinary Article 55 rule gives two periods. The practical consequence for a company that began importing before registering: the import documentation must be assembled before the first return is filed, not after.

The refund procedure and its deadlines are analysed in UAE VAT Refund for Businesses in 2026.

What Changes on 1 October 2026: Article 54 bis and Supplier Verification

From 1 October 2026, Federal Tax Authority Decision No. 13 of 2026 takes effect, setting the measures, procedures and conditions a taxable person must complete to verify the validity and integrity of the supplies it receives before deducting input tax. The decision was approved at the 45th meeting of the Federal Tax Authority Board on 23 June 2026, issued on 22 July 2026 and published on 20 August 2026.

The legal basis is the new Article 54 bis of the VAT Law, inserted by Federal Decree-Law No. 16 of 2025 with effect from 1 January 2026. Its text, verbatim:

“1. The Authority shall reject the deduction of the Recoverable Input Tax if it is established to the Authority that the supply subject to the deduction was part of a supply or a chain of supplies related to Tax Evasion, and the Taxable Person was aware of this relation upon deducting the Recoverable Input Tax. 2. The Authority mayreject the deduction of the Recoverable Input Tax if it is established to the Authority that the supply subject to the deduction was part of a supply or a chain of supplies related to Tax Evasion, and the Taxable Person should, based on circumstances of the supply, have been aware of this relation. 3. For the purposes of applying the provisions of Clause 2 of this Article, the Taxable Person shall be considered to have been required to be aware that the supply was part of a supply or a chain of supplies related to Tax Evasion, if he did not verify the validity and integrity of the supplies he receives before deduction of Input Tax, in accordance with the measures, procedures and conditions determined by the Authority in this regard.”

Clause 3 is a deeming provision, and the whole construction turns on it. Failing to perform the checks does not merely weaken the taxpayer’s position in a dispute — it is treated as satisfying the “should have known” limb of clause 2, which switches on the authority’s power to refuse the deduction. Author’s assessment: this is a knowledge test on the European model, but with a procedural presumption in the authority’s favour: what has to be proved is not knowledge, but failure to follow the procedure.

What Decision No. 13 of 2026 actually requires. Article 3 — verifying the supplier.

What is checked	Requirement
Identity of a supplier that is a natural person	Obtain a copy of valid proof of identity (Emirates ID or passport) and meet the supplier, in person or virtually, before the supply is made
Identity of a supplier that is a legal person	Verify incorporation through official databases or obtain a copy of the certificate of incorporation, provided the details match the entity’s name, address and employees; verify the identity of the director, agent or authorised employee by a copy of an Emirates ID or passport
Address and place of business	Verify the existence of an actual place of business by appropriate electronic means or by a field visit; ensure the place of business is compatible with the nature of the activities
Risk level	Ensure none of three indicators applies: the supplier has changed address more than twice in the previous 12 months; has changed key employees more than twice in the previous 12 months; or has undertaken transactions dispro­po­rtionate or unexpected in volume, value or nature relative to the size of its business and its trading history
Bank account and reputation — where supplies exceed AED 375,000 over the previous 12 months, or are expected to exceed AED 375,000 over the next 12	Obtain written confirmation from an authorised UAE bank that the supplier holds an account, free of reservations or conditions; review publicly available reviews and media coverage from reliable sources

Where a risk indicator applies, the taxable person must retain a clear and justified explanation of its applicability and submit it to the authority on request, provided the indicators do not contradict the evidence or information available to the taxable person.

Article 4 — verifying the supply itself. A general assessment of the transaction’s conditions and confirmation that the supplier’s engagement rests on genuine commercial reasons. Assessment of payment conditions: the method and terms must be commercially justifiable, and where a third party is involved in making or receiving payment, or where payment is made to a bank account outside the supplier’s country of incorporation, a reasonable commercial explanation is required. Consideration must be paid by electronic means; cash is permissible only where there is a documented commercial reason, within the thresholds in the tax legislation, and where easily verifiable. Verification of the supply’s circumstances: prices and margins must not be commercially unjustifiable or significantly different from market conditions without a clear reason; the goods or services must not fall outside the supplier’s ordinary activity or its licensed activities; the authenticity and origin of the goods received must be verified, along with the validity of the supplier’s ownership of the goods or its right to dispose of them; and where the supplier acts as an intermediary, there must be a clear and justifiable commercial explanation for its role.

Article 4(3)(c) is the provision that stitches the tax check directly onto import documentation. “Verify the authenticity and origin of the Goods received, as well as the validity of the supplier’s ownership of Goods or their right to dispose of such Goods.” The practical consequence: importers and distributors must hold origin and title evidence for VAT purposes independently of the customs declaration — and hold it in a form that can be produced on request.

Article 5 — frequency and organisation. The Article 3 supplier check is performed on first dealing with a supplier, or on recurrent dealings where the supplier has not been verified in the previous 12 months. The Article 4 check is performed on every taxable supply received. The verification steps must be documented, with supporting documents and records retained so the authority can confirm they were carried out correctly. A documented policy must be maintained, identifying the persons responsible for implementing, reviewing and supervising the procedures, and setting out their powers and responsibilities clearly. The requirements for keeping and retaining a company’s accounting records are analysed in Corporate Audit Requirements in the UAE 2026.

Article 6 — exceptions. The verification procedures may be disregarded where the consideration, exclusive of VAT, is less than AED 10,000. That exception does not apply where the total value of supplies received from the supplier exceeds AED 100,000 over the previous 12 months, or is expected to exceed that amount over the next 12.

Decision No. 13 carries no penalty of its own — and that is fundamental. The consequence sits entirely in Article 54 bis(3): failing the checks engages the “should have known” deeming rule, which gives the authority the power to refuse the deduction. A refusal produces a shortfall, and a shortfall attracts the ordinary penalties — the 14 per cent per annum charge and, if a voluntary disclosure is not filed before notification of an audit, a fixed 15 per cent plus 1 per cent per month. Where the refused input tax is import VAT, a separate line of the penalties table applies — 50 per cent of the unpaid or undeclared tax.

A new class of instrument that appeared in July 2026 is also worth knowing about. The Federal Tax Authority has begun issuing Directives on Tax Transactions, under its own Decision No. 5 of 2021 on issuing clarifications and directives and the policy set by Decision No. 2 of 2025 (in force from 1 March 2025). The first five were issued in July 2026: No. 1 on judicial expert services; No. 2 on adjustments of output and input tax following a member’s exit from a tax group (in force from 1 August 2026); No. 3 on converting values in digital currencies into dirhams; No. 4 on fees forming part of a life insurance contract; and No. 5 on determining the value of deemed supplies of services. None of the five touches importation, customs or Designated Zones — the whole of the 2026 regulatory activity on cross-border goods sits in Article 54 bis and Decision No. 13.

What an Error Costs: the Penalties That Changed on 14 April 2026

Administrative penalties for tax violations in the UAE are set by Cabinet Decision No. 40 of 2017. It has never been replaced — it has been amended three times, and the latest amendment has been in force since 14 April 2026.

The chain appears verbatim on the cover page of the consolidated text.

Instrument	Issued	In force
Cabinet Decision No. 40 of 2017	24 September 2017	24 September 2017
Cabinet Decision No. 49 of 2021	28 April 2021	28 June 2021
Cabinet Decision No. 108 of 2021	30 December 2021	1 January 2022
Cabinet Decision No. 129 of 2025	9 October 2025	14 April 2026

Two common misconceptions sit here at once. First, Cabinet Decision No. 40 of 2017 was not replaced by Cabinet Decision No. 49 of 2021 — it was amended by it. Second, the second amendment was Cabinet Decision No. 108 of 2021, not No. 105 of 2021; Cabinet Decision No. 105 of 2021 is a separate instrument on instalments and waiver of administrative penalties, and it operates in its own right.

The import-relevant penalties — Table 1 of the consolidated text (Tax Procedures Law violations).

Row	Violation	Penalty
15	Failure of the person to calculate any tax that may be due on the import of goods as per the tax law	50 per cent of the unpaid or undeclared tax
14	Failure of a registrant to calculate tax on behalf of another person where it is obliged to do so	A monthly penalty of 14 per cent per annum for each month or part thereof on the unsettled amount, from the day after the due date and on the same date monthly thereafter
9	Failure of a registrant to settle the payable tax within the timeframe specified in the tax law	A monthly penalty of 14 per cent per annum for each month or part thereof on the unsettled payable amount, from the day after the due date and on the same date monthly thereafter. For voluntary disclosure and tax assessment purposes, the due date means 20 working days from submission or receipt respectively
8	Failure to submit the tax return within the specified timeframe	AED 1,000 for the first time; AED 2,000 on repetition within 24 months
10	Submission of an incorrect tax return	AED 500, unless the taxable person corrects the return within the filing deadline or submits a voluntary disclosure that produces no difference in the tax due
11	Submission of a voluntary disclosure on errors in a return, assessment or refund application	1% per month on the tax difference for each month or part thereof, from the day after the due date of the return, or of the submission of the refund application, until the voluntary disclosure is filed
12	Failure to submit a voluntary disclosure before being notified by the authority of a tax audit	A fixed 15% of the tax difference plus 1% per month on the tax difference for each month or part thereof
1	Failure to keep the required records and information	AED 10,000 per violation; AED 20,000 on repetition within 24 months
2	Failure to submit tax data, records and documents in Arabic	AED 5,000
13	Failure to facilitate a tax audit	AED 20,000

Table 3 — the VAT-specific violations, and it has become very short.

Row	Violation	Penalty
1	Failure of the taxable person to display prices inclusive of tax	AED 5,000
2	Failure to notify the authority of applying the profit margin scheme	AED 2,500
3	Failure to comply with the required conditions and procedures relating to keeping goods in a Designated Zone or moving them to another Designated Zone	The higher of AED 50,000 or 50 per cent of the tax chargeable on the goods, if applicable
4	Failure to issue a tax invoice or alternative document within the period specified	AED 2,500 for each detected case
5	Failure to issue a tax credit note or alternative document within the period specified	AED 2,500 for each detected case
6	Failure to comply with the conditions and procedures for issuing a tax invoice and credit note ele­ctroni­cally	AED 2,500 for each detected case

Row 3 of Table 3 is the most expensive VAT-specific penalty for a warehousing model, and it attaches to procedure rather than to tax. It bites on failure to comply with the conditions and procedures for keepinggoods in a Designated Zone or moving them to another zone — that is, on breach of the zone’s operating regime, not on non-payment of tax. The arithmetic runs as follows: the penalty is taken on the tax chargeable on the goods, and that tax is 5 per cent of value, so the percentage limb equals 2.5 per cent of the consignment value. It exceeds the fixed AED 50,000 only where the goods are worth more than AED 2,000,000 — that is, where the tax on the consignment exceeds AED 100,000. On every smaller consignment the fixed AED 50,000 applies. Author’s assessment: that is precisely why the penalty is disproportionately large on minor breaches — on a consignment worth AED 200,000 the tax is AED 10,000 and the penalty is still AED 50,000.

Row 15 of Table 1 — the 50 per cent — is expressed for the import of goods. A failure to apply the reverse charge to imported services is normally treated as an error in the return and runs through rows 10 to 12, not row 15. The difference is material: 50 per cent against 15 per cent plus 1 per cent per month.

The row 9 charge was completely rewritten on 14 April 2026. It accrues from the day after the due date and re-applies monthly on the same date; a part-month counts as a whole month. There is no immediate one-off percentage in the current text. The former construction was set by row 9 of Table 1 to Cabinet Decision No. 49 of 2021 and read: “2% of the unpaid Tax shall be due on the day following the due date of payment”, plus “4% monthly penalty is due after one month from the due date of payment, and on the same date monthly thereafter”, capped at 300 per cent. Material presenting that model as current is describing a version that ceased to apply on 14 April 2026. Note that the Ministry of Finance consolidation does not preserve the superseded wording — it has to be read in Cabinet Decision No. 49 of 2021 itself.

The instalment and penalty-waiver mechanism is operational. It rests on Cabinet Decision No. 105 of 2021, and the service is available in EmaraTax. The conditions per the official service page: instalments require unsettled penalties of AED 50,000 or more, the underlying violation to have been corrected with an undertaking not to repeat it, and no payable tax outstanding for the affected period; waiver runs on the criteria in Article 4 of Cabinet Decision No. 105 of 2021. Common conditions: the penalty must be unsettled and not under dispute before the Tax Disputes Resolution Committee or the courts. A decision is issued within a period not exceeding 110 working days, and the service is free.

Separately from the tax penalties, two temporary Dubai Customs measures are running in 2026 that importers need to know about, because both are limited by an application deadline.

Measure	Notice	Substance	Who qualifies	Application deadline
80 per cent reduction of customs fines	No. 15/2026, issued 27 June 2026, effective from 21 May 2026	An 80 per cent reduction of financial penalties in customs cases; the remaining 20 per cent is payable	Penalty decisions issued before 28 February 2026. Does not apply to cases already in litigation or dispute	Application by 31 December 2026; payment in full by 30 June 2027, with instalments by exception
Instalments for outstanding customs duty	No. 14/2026, issued 27 June 2026, effective from 21 May 2026	Payment of outstanding customs duty by instalments over up to one year from the date of approval	Import declarations issued between 1 March and 30 June 2026 using a credit account	Application by 30 September 2026

The fine-reduction measure applies to financial penalties only and does not touch the customs duty itself or administrative fees. Where the payment schedule is missed or a dispute arises, Dubai Customs may revoke the approval, demand immediate payment in full, impose penalties, suspend customs transactions and pursue legal action.

Note the date construction: both notices were issued on 27 June 2026 but take effect retrospectively from 21 May 2026. Both are expressly described as temporary and tied to business-support measures. Author’s assessment: a company carrying accumulated customs fines, or duty arrears from spring 2026, has a limited window — and it closes on 30 September 2026 for the instalment facility and on 31 December 2026 for the fine reduction.

The appeal route and voluntary disclosure practice are analysed in UAE Tax Penalties, Voluntary Disclosure and Appeals in 2026.

Step-by-Step: From Licence to Recovering Import VAT

Getting the sequence right saves time rather than money: half the problems with import VAT arise because the tax and customs numbers are linked after the first shipment rather than before it.

1.        Choose the emirate and the site before incorporating. If the model is warehousing and stock will be held pending resale, check the site against the Designated Zones list (24 zones, table above), not against the zone’s marketing material.

2.        Check that the licence activity covers importing and trading the specific goods — your own licence, and from 1 October 2026 your supplier’s as well. Article 4(3)(b) of Decision No. 13 of 2026 requires the goods not to fall outside the supplier’s licensed activity, so a counterparty’s licence scope becomes your tax question too.

3.        Obtain the Business Code from the emirate’s customs department. In Dubai, Request Business Registration through Dubai Trade: AED 100 plus AED 20, one working day, trade licence, passport and Emirates ID of the authorised person.

4.        Check that the Business Code’s validity matches the licence’s, and set the licence renewal reminder ahead of the code renewal reminder: the code cannot be renewed before the licence.

5.        Register for VAT if you have not already.

6.        Link the customs registration number to the TRN in EmaraTax through a registration amendment. Budget working weeks: amendments requiring approval take up to 20 working days.

7.        Open a duty account if volumes are regular: a credit account (minimum AED 10,000) or a Standing Guarantee account (minimum AED 25,000). The service is free and a new account takes one working day.

8.        Classify the goods before shipment. From August 2026 rest-of-world imports move into phase 3 of the 12-digit tariff. Check the code in Al Munasiq and reconcile it against the tariff.

9.        Check whether the goods are prohibited or restricted and obtain the permit from the competent authority in advance: the list of authorities differs by emirate.

10.    Check whether a CEPA preference applies, and under which emirate customs notice it was brought into operation — the notice date, not the signature date, is the operative one.

11.    Choose the customs regime deliberately. Release into free circulation, temporary admission, warehousing, transit or import-for-re-export is simultaneously a choice about when the VAT obligation arises (Article 47 of the Executive Regulation).

12.    Lodge the declaration in Mirsal 2 and pay the duty. An ordinary dutiable import declaration costs AED 90 including the knowledge and innovation fee.

13.    Make sure the importer named on the declaration is the person who should get the deduction. The Article 1 definition of Importer attaches to the name on the declaration.

14.    File supporting documents with customs within 14 days — delay costs AED 50 a day, up to 90 days.

15.    Check Box 6 in the VAT return against your own import declarations for the period, and correct any divergence through Box 7.

16.    Assemble the recovery documents: the supplier’s invoice plus the customs document — the “statement from the relevant Customs Department” under Article 48(5)(b) of the Executive Regulation. Where an agent cleared the cargo, obtain the Article 50(7) statement.

17.    Claim the deduction in the first period in which the Article 55 conditions are met, or in the one after. There is no third period.

18.    Where the supply comes from a new supplier, complete the Decision No. 13 checks before deducting,document them, and hold a written policy with named individuals responsible for it. From 1 October 2026, failing to perform the checks itself triggers the “should have known” deeming rule.

19.    Process inter-Designated-Zone movements under customs suspension, not as an “internal transfer”: Article 51(3)(b) of the Executive Regulation conditions the tax neutrality on compliance with the customs rules.

20.    Take stock counts in the zone regularly. A shortage is a standalone ground for a deemed import under Article 51(9)(b).

Common Mistakes and What They Cost

Mistake 1. Not linking the customs number to the TRN, and finding out at the port. The Article 48(1)(c) condition is unmet, Article 50(1) bites, and the tax must be paid before release. Cost: not a lost deduction but frozen working capital on every shipment, plus up to 20 working days to correct the registration details while the cargo sits.

Mistake 2. Computing VAT on the CIF value without the customs duty. Article 35 expressly brings “any customs fees and Excise Tax paid on the Import of the Goods” into the base. Cost: a systematic underpayment, penalised under row 15 of Table 1 at 50 per cent of the unpaid or undeclared tax — before the 14 per cent per annum charge under row 9.

Mistake 3. Letting the forwarder name itself as importer and recover the VAT in its own return. Article 50(6) of the Executive Regulation expressly bars an agent from recovering tax paid on behalf of another person. Cost: the deduction is refused to the agent, and the owner has no document to support its own deduction unless the Article 50(7) statement was issued; putting it right requires Box 7 adjustments by both parties and a written agreement between them.

Mistake 4. Assuming a free zone is automatically a Designated Zone. DMCC, DIFC, Dubai Silicon Oasis, Dubai Media City, d3, DWTC and Masdar City do not appear in the Cabinet Decision No. 59 list. Cost: a warehousing model built on “the goods are outside the UAE until sold” collapses — the goods were imported into the UAE on entering the zone, the import VAT arose then, and it was not declared.

Mistake 5. Moving goods between two Designated Zones as an “internal transfer”. Article 51(3)(b) requires the movement to follow the customs suspension rules of the GCC Common Customs Law. Cost: row 3 of the VAT penalties table — the higher of AED 50,000 or 50 per cent of the tax chargeable on the goods.

Mistake 6. Taking stock from the zone for the company’s own use and not recording it. Article 51(9)(a) turns consumption by the owner into a deemed import. Cost: undeclared import VAT with all the row 15 consequences, on a transaction that looked like an internal movement and was never booked.

Mistake 7. Missing the recovery window and simply putting the deduction in a later return. Article 55 gives the first period and the one after it, and no more. Cost: correction is only possible by voluntary disclosure for the correct period, at 1 per cent per month of the tax difference — plus a fixed 15 per cent if filed after notification of an audit.

Mistake 8. Applying the AED 300 e-commerce threshold, or assuming the AED 1,000 threshold is federal. The AED 1,000 threshold was introduced by Dubai Customs Notice No. 16/2026 from 3 August 2026 and is the Dubai position; its application in other emirates could not be confirmed from official sources. Cost: underpaid duty on consignments cleared through another emirate, or conversely overpayment in Dubai and a refund claim taking 5 working days and costing AED 70.

Mistake 9. Assuming duty relief also relieves VAT. The two thresholds are set by different instruments and different authorities. Cost: a parcel worth AED 900 clears free of duty and remains within the scope of VAT; on a regular flow this accumulates into undeclared import tax.

Mistake 10. Modelling the late-payment charge as “2 per cent immediately plus 4 per cent monthly”. Since 14 April 2026 the charge is a monthly penalty of 14 per cent per annum running from the day after the due date. Cost: a wrong estimate of what lateness costs, which is precisely the estimate that determines whether to file a voluntary disclosure now or keep gathering documents.

Mistake 11. Treating the Decision No. 13 supplier checks as a formality. Article 54 bis(3) converts non-performance into a presumption of awareness of tax evasion in the chain. Cost: refusal of input tax across the whole chain of supplies from that supplier, not on a single transaction.

Mistake 12. Treating the AED 10,000 threshold in Article 6 of Decision No. 13 as unconditional. The exception does not apply once total supplies from the supplier exceed AED 100,000 over the previous 12 months, or are expected to over the next 12. Cost: a supplier billed at AED 9,000 a month crosses AED 100,000 on a rolling twelve-month view in the twelfth month — and every earlier “small” purchase turns out, retrospectively, to have been unverified.

Mistake 13. Renewing the Business Code independently of the licence. The code cannot be renewed ahead of the licence. Cost: an inability to lodge declarations in your own name between licence expiry and renewal — cargo standing, and on regular shipments, demurrage.

Mistake 14. Citing superseded instruments on the corporate tax side of the structure. Cabinet Decision No. 55 of 2023 was repealed by Article 10 of Cabinet Decision No. 100 of 2023; Ministerial Decision No. 265 of 2023 was repealed by Article 6 of Ministerial Decision No. 229 of 2025. Cost: a qualifying-activity analysis built on a repealed list — and the zero corporate tax rate turns on that analysis.

Who This Suits, Who It Does Not, and When Professional Review Is Needed

The UAE import regime favours distributors and re-exporters, is neutral for a domestic retail importer, and works against a company importing for consumption inside a free zone that does not hold Designated Zone status.

It suits:

•          re-export and transit models — import-for-re-export, transit and temporary admission suspend duty and VAT together, and on re-export the security is released where the goods leave within six months;

•          warehousing and distribution models in zones on the Designated Zones list — the goods are treated as outside the UAE until moved into the local market, and resale within the zone is not consumption;

•          regular importers with a VAT-registered entity and linked numbers — the reverse charge makes import VAT cash-neutral;

•          e-commerce with small parcels in Dubai — the AED 1,000 threshold from 3 August 2026 takes duty off the bulk of B2C shipments.

It does not suit:

•          companies in free zones outside the Designated Zones list building a warehousing model — DMCC, DIFC, DSO, Dubai Media City, d3, DWTC and Masdar hold no such status, and entry into them is entry into the UAE;

•          importers not registered for VAT — the tax is paid before release, and without subsequent registration it is not recovered at all;

•          models where the final destination of the goods is another GCC Implementing State — tax under Article 48(2) is not recoverable, by force of Article 54(4);

•          businesses buying heavily from new and small suppliers — from 1 October 2026 every such supply requires a documented check under Decision No. 13.

Professional review is needed: when choosing a warehousing site; when building a chain with an agent or forwarder named as importer on the declaration; on movements between zones; when a shortage is found in zone stock; when the recovery window has been missed; when planning a voluntary disclosure; and when designing the supplier verification procedure required by Decision No. 13 of 2026.

Frequently Asked Questions

How much does a customs code cost in Dubai and how often is it renewed?

Registering a new Business Code costs AED 100 plus the AED 20 Knowledge and Innovation fee, AED 120 in total; renewal is AED 25 with no additional fee, the amount being below the AED 50 threshold. Processing takes 1 working day. Renewal frequency is set not by the calendar but by the trade licence: the code lasts as long as the licence and can only be renewed after the licence itself has been renewed.

Is a customs code needed if a broker handles clearance?

No — the declaration can be lodged under a licensed customs broker’s code. But the broker is then the importer on the declaration, and the Article 1 definition of Importer in the VAT Law attaches to the name on the declaration. That changes whose VAT return the import VAT lands in, and requires either Box 7 adjustments by both parties or the agent’s statement under Article 50(7) of the Executive Regulation.

Is import VAT charged on the goods value or on the duty-inclusive value?

On the duty-inclusive value. Article 35 of the VAT Law brings into the base the customs value, insurance, freight, any customs fees and excise tax paid on the import. The VAT itself is excluded from its own base. On CIF of USD 105,000 with 5 per cent duty, the VAT base is USD 110,250.

Can payment of import VAT at the border be deferred?

Yes, where the importer is VAT-registered and the four conditions in Article 48(1) of the Executive Regulation are met, including giving the tax authority its own customs registration number. The tax is then accounted for in the return under the reverse charge. If any condition fails, Article 50(1) applies and the tax is paid before the goods are released.

Is my free zone a Designated Zone?

Check it against the list published by the Federal Tax Authority under Cabinet Decision No. 59 of 2017 as amended five times. The list runs to 24 zones currently listed. JAFZA, DAFZA, KIZAD, Hamriyah, SAIF, Ajman Free Zone, Fujairah Free Zone and FOIZ are on it. DMCC, DIFC, Dubai Silicon Oasis, Dubai Media City, d3, DWTC and Masdar City are not. Being listed is not the only condition: the zone must in fact meet the requirements of Article 51(1) of the Executive Regulation.

Are services inside a Designated Zone taxable?

Yes. Article 51(6) of the Executive Regulation: the place of supply of any services is considered to be inside the UAE if it falls in a Designated Zone. Zone status places only goods outside the UAE. Water and any form of energy are treated like services under clause 8.

In which period is import VAT recovered?

In the return for the first tax period in which the Article 55(1) conditions are met, or the one immediately following. For imported goods the conditions include receiving and retaining invoices and import documents for an import on which the tax was paid or declared. The specific customs document is the “statement from the relevant Customs Department” under Article 48(5)(b) of the Executive Regulation.

What changed with the duty-free threshold for online orders?

From 3 August 2026 the Dubai threshold is AED 1,000 — Dubai Customs Notice No. 16/2026 of 30 July 2026. Tobacco and tobacco products, electronic nicotine delivery systems, devices and accessories, nicotine-containing liquids, alcoholic beverages and food preparations containing alcohol are excluded. Returns through B2C companies are duty-exempt within 60 days of export. This is an instrument of the Dubai customs department, not a federal act, and relief from duty does not relieve import VAT.

What additional work starts on 1 October 2026?

Verifying the supplier and the supply before deducting input tax, under Federal Tax Authority Decision No. 13 of 2026: the supplier’s identity and incorporation, an actual place of business, three risk indicators, and — where supplies exceed AED 375,000 over 12 months — bank confirmation and a review of public reputation; and on every supply, commercial rationale, electronic payment, market-consistent pricing, and the authenticity, origin and title of the goods. The supplier check repeats at least every 12 months and the supply check applies to every taxable supply. The AED 10,000 exception falls away once supplies from that supplier exceed AED 100,000 over 12 months.

What does late payment of tax cost in 2026?

A monthly penalty of 14 per cent per annum for each month or part of a month, running from the day after the due date and re-applying on the same date monthly — row 9 of Table 1 to Cabinet Decision No. 40 of 2017 as amended by Cabinet Decision No. 129 of 2025, in force from 14 April 2026. Separately: failure to calculate tax due on the import of goods carries 50 per cent of the unpaid or undeclared tax.

Is a customs code from one emirate valid in another?

No published rule settles the point either way. Each emirate runs its own customs department, its own declaration system and its own registration service. In practice a company clearing cargo through the ports of several emirates registers with each of those customs departments.

Can import VAT paid before VAT registration be recovered?

Yes, but there is one window. Article 56 of the VAT Law allows input tax on goods imported before the registration date to be claimed in the return for the first tax period after registration, provided the goods were used for supplies giving the right of recovery. The five-year bar in Article 56(2) is drafted for services, not goods.

Key Takeaways

•          Duty is 5 per cent of CIF under Federal Law No. 19 of 2002; tobacco is 100 per cent; alcohol is 50 per cent per the government portal, unconfirmed by a tariff line.

•          The VAT base is CIF plus duty plus excise, Article 35 of the VAT Law; the VAT is excluded from its own base.

•          Dubai Business Code: AED 120 to register, AED 25 to renew, 1 working day, validity equal to the licence’s.

•          An ordinary dutiable import declaration costs AED 90 including the Knowledge and Innovation fee.

•          The reverse charge has four conditions, and the decisive one is the customs registration number given to the tax authority.

•          Designated Zones number 24 on the Federal Tax Authority’s consolidated list; DMCC, DIFC, DSO, DWTC, d3, Dubai Media City and Masdar are not among them.

•          Services inside a Designated Zone are taxed as if in the UAE; the status places only goods outside the UAE.

•          The recovery window is two tax periods, and no more.

•          From 3 August 2026 the Dubai e-commerce duty-free threshold is AED 1,000, with tobacco, nicotine and alcohol carved out.

•          From 14 April 2026 the late-payment charge is 14 per cent per annum monthly; failing to calculate tax on the import of goods costs 50 per cent.

•          From 1 October 2026 a mandatory supplier verification procedure precedes any input tax deduction.

Summary

Importing goods into the UAE in 2026 runs through two parallel circuits. The customs circuit rests on the Common Customs Law of the GCC States, ratified by Federal Decree No. 85 of 2007, and on Federal Law No. 19 of 2002, whose Article 1 set the duty rate at 5 per cent of the CIF value from 1 January 2003; tobacco is charged at 100 per cent under Federal Law No. 11 of 1981 as amended by Federal Law No. 2 of 1998; and 53 commodities are exempt under Article 2 of Federal Law No. 19 of 2002. The Federal Customs Authority no longer exists: Federal Decree-Law No. 14 of 2021 repealed Federal Law No. 8 of 2015 and transferred its competences to the Federal Authority for Identity, Citizenship, Customs and Port Security, while execution remained at emirate level. In Dubai an importer obtains a Business Code for AED 120 (renewal AED 25, one working day, validity equal to the trade licence’s) and lodges its declaration in Mirsal 2, in operation since 24 March 2010; an ordinary dutiable import declaration costs AED 70 plus the AED 20 Knowledge and Innovation fee. From 3 August 2026 Dubai Customs Notice No. 16/2026 exempts goods worth no more than AED 1,000 from customs duty in cross-border e-commerce, except tobacco, electronic smoking devices, nicotine-containing liquids, alcohol and food preparations containing alcohol, and exempts returns through B2C companies within 60 days. The tax circuit is governed by Federal Decree-Law No. 8 of 2017 as amended, most recently by Federal Decree-Law No. 16 of 2025 in force from 1 January 2026, which inserted Article 54 bis and removed the self-invoicing requirement under the reverse charge. Import VAT is 5 per cent of a base that under Article 35 comprises the customs value, insurance, freight, customs fees and excise tax. A registered importer does not pay at the border where the four conditions of Article 48(1) of the Executive Regulation are met, including giving the Federal Tax Authority its own customs registration number; otherwise Article 50(1) applies and the tax is paid before release. Designated Zones are set by Cabinet Decision No. 59 of 2017 as amended by Decisions No. 35 of 2018, No. 43 of 2019 and Nos. 34, 63 and 81 of 2021; 24 zones are live, and DMCC, DIFC, Dubai Silicon Oasis, Dubai Media City, d3, DWTC and Masdar are not among them. A zone is outside the UAE for goods only: Article 51(6) of the Executive Regulation places the supply of any services in a Designated Zone inside the UAE. Import VAT is recovered under Article 55 in the first period in which the conditions are met, or the next, on the strength of the invoice and the customs document. From 14 April 2026, under Cabinet Decision No. 129 of 2025, the late-payment charge is 14 per cent per annum applied monthly, and failing to calculate tax on the import of goods costs 50 per cent of the unpaid or undeclared tax. Two temporary Dubai Customs measures also run in 2026: Customs Notice No. 15/2026 of 27 June 2026 reduces customs fines by 80 per cent on decisions issued before 28 February 2026, with applications due by 31 December 2026, while Customs Notice No. 14/2026 of the same date allows customs duty to be paid by instalments over up to one year on declarations issued between 1 March and 30 June 2026, with applications due by 30 September 2026. From 1 October 2026 Federal Tax Authority Decision No. 13 of 2026 requires the supplier and the supply to be verified before input tax is deducted, and failing those checks is, under Article 54 bis(3), treated as ground to conclude that the taxpayer should have known of tax evasion in the chain.

If you are planning an import model, a warehousing site or a distribution structure in the UAE, the UPPERSETUP team can take you from choosing the emirate and the zone through to linking the customs and tax numbers: company registration in the UAE.

Sources

UAE federal legislation

1.        Federal Decree-Law No. 8 of 2017 on Value Added Tax — consolidated text with amendments, Federal Tax Authority publication of 28 November 2025

2.        Federal Decree-Law No. 8 of 2017 — instrument record on the UAE legislation portal

3.        Federal Decree-Law No. 8 of 2017 — full text, UAE legislation portal

4.        Federal Decree-Law No. 8 of 2017 and its amendments — Ministry of Finance consolidated text

5.        UAE Ministry of Finance: Federal Decree-Law No. 16 of 2025 — VAT Law amendments from 1 January 2026

6.        Federal Decree-Law No. 14 of 2021 establishing the Federal Authority for Identity, Citizenship, Customs and Port Security — instrument record

7.        Federal Decree-Law No. 14 of 2021 — full text

8.        Federal Law No. 19 of 2002 on customs duty on goods imported from outside the Customs Union into the GCC states — instrument record

9.        Federal Law No. 19 of 2002 — full text with the schedule of exempt commodities

10.    Federal Law No. 11 of 1981 imposing federal customs duty on imports of tobacco — instrument record

11.    Federal Law No. 11 of 1981 — full text as amended by Federal Law No. 2 of 1998

12.    Federal Law No. 11 of 2019 on the Rules and Certificates of Origin — instrument record

13.    Federal Law No. 11 of 2019 — full text

14.    Federal Law No. 1 of 2017 on Anti-Dumping, Countervailing and Safeguard Measures — full text

15.    Federal Decree-Law No. 43 of 2021 on Goods Subject to Non-Proliferation (repealing Federal Law No. 13 of 2007) — full text

16.    Federal Decree-Law No. 26 of 2024 repealing certain federal laws — full text

Subordinate instruments

17.    Cabinet Decision No. 52 of 2017 — the VAT Executive Regulation, consolidated text with amendments, Ministry of Finance, October 2025

18.    The Executive Regulation — consolidated text, Federal Tax Authority publication of 18 September 2025

19.    Cabinet Decision No. 52 of 2017 — instrument record on the UAE legislation portal

20.    Cabinet Decision No. 40 of 2017 on administrative penalties as amended by Nos. 49 of 2021, 108 of 2021 and 129 of 2025 — consolidated text, Ministry of Finance, 14 November 2025

21.    Cabinet Decision No. 49 of 2021 on administrative penalties — the version in force until 14 April 2026, with the 2 per cent plus 4 per cent monthly model and the 300 per cent cap

22.    Cabinet Decision No. 100 of 2023 on determining Qualifying Income for the Qualifying Free Zone Person

23.    Ministerial Decision No. 229 of 2025 on Qualifying Activities and Excluded Activities (repealing Ministerial Decision No. 265 of 2023)

24.    Cabinet Decision No. 153 of 2025 on applying the reverse charge mechanism to metal scrap

Federal Tax Authority instruments and publications

25.    Federal Tax Authority Decision No. 13 of 2026 on the measures, procedures and conditions for verifying the validity and integrity of supplies before deducting input tax

26.    Federal Tax Authority legislation library

27.    List of Designated Zones for VAT purposes — Federal Tax Authority consolidated publication as at 21 September 2021

28.    VAT Guide VATGDZ1, “Designated Zones”

29.    Public Clarification VATP027, “Goods supplied in a Designated Zone, and connected shipping or delivery services”

30.    Public Clarification VATP012, “Importation of goods by agents on behalf of VAT registered persons”

31.    Public Clarification VATP044, “Concerned Services — Tax invoices and input tax recovery”, 26 May 2025

32.    Public Clarification VATP040 on the Executive Regulation amendments made by Cabinet Decision No. 100 of 2024, 14 March 2025

33.    Public Clarification VATP017, “Time-frame for recovering Input Tax” — Federal Tax Authority page

34.    VAT Import Declaration User Guide, version 6.0, January 2022

35.    EmaraTax FAQs — linking the customs registration number to the TRN

36.    VAT records amendment — Federal Tax Authority service page

37.    Registration of customs clearance companies (TINCO / TINCE) — service page

38.    Administrative penalty waiver request — service page

39.    Filing VAT returns and making payments — Federal Tax Authority page

40.    VAT Returns User Guide, version 4.0

41.    Corporate Tax Guide CTGFZP1, “Free Zone Persons”, May 2024

GCC Common Customs Law

42.    Common Customs Law of the GCC States and its Rules of Implementation — GCC Secretariat General

Dubai Customs notices and publications

43.    Customs Notice No. 16/2026 of 30 July 2026 — the AED 1,000 cross-border e-commerce threshold, effective 3 August 2026

44.    Customs Notice No. 10/2026 of 23 April 2026 — UAE PASS for signing customs declarations from 10 May 2026

45.    Customs Notice No. 13/2026 of 24 June 2026 — temporary ban on exporting industrial-use waste

46.    Customs Notice No. 15/2026 of 27 June 2026 — the temporary 80 per cent reduction of customs fines, effective from 21 May 2026

47.    Customs Notice No. 14/2026 of 27 June 2026 — the temporary instalment facility for outstanding customs duty, effective from 21 May 2026

48.    Customs Notice No. 04/2026 of 14 March 2026 — the Green Corridor with Oman

49.    Customs Notice No. 06/2026 of 4 April 2026 — extension of the Green Corridor arrangement

50.    Customs Notice No. 02/2026 of 30 January 2026 — continued use of 8-digit HS codes

51.    Customs Notice No. 01/2026 of 30 January 2026 — implementing the UAE–Vietnam CEPA from 3 February 2026

52.    Customs Notice No. 07/2026 of 8 April 2026 — amendment to the anti-dumping measure on batteries

53.    Customs Notice No. 01/2024 of 9 January 2024 — implementing the GCC Unified Customs Tariff amendments under Cabinet Decision No. 123 of 2023

54.    Customs Notice No. 08/2023 of 31 August 2023 — implementing the UAE–Indonesia CEPA

55.    Dubai Customs Service Guide, version 9, 2025 — registration, declaration (Appendix B), inspection and refund fees

56.    Dubai Customs Customer Guide — client code categories, duty accounts, guarantees and deposits

57.    Dubai Customs Passenger Customs Guide, version 6, 2025 — traveller allowances and the AED 3,000 figure

58.    Dubai Customs Policies — consolidated document, including DCP(18) on release before completion of procedures

59.    Dubai Customs Integrated Customs Tariff — the 12-digit nomenclature, version 4

60.    Implementation phases for 12-digit HS codes — Dubai Customs

61.    Launch of Mirsal 2 — Dubai Customs press release

62.    Al Munasiq — the Dubai Customs goods classification platform

63.    Client registration with Dubai Customs — service page

64.    Dubai Trade — registration with Dubai Customs

65.    Dubai Trade — submit a customs declaration

66.    Dubai Trade — request a duty account

67.    Dubai Trade — submit a refund claim

Official portals and emirate customs authorities

68.    UAE government portal: clearing the customs and paying customs duty

69.    Federal Authority for Identity, Citizenship, Customs and Port Security — overview of UAE customs

70.    Legal instruments register of the Federal Authority for Identity, Citizenship, Customs and Port Security — the Legal Affairs page (as at August 2026 it still lists repealed instruments)

71.    Abu Dhabi Customs — restricted and banned commodities

72.    Sharjah Customs — importer/agent code

73.    UAE Ministry of Economy and Tourism — Comprehensive Economic Partnership Agreements

74.    UAE foreign trade portal

A note on sources and levels of confirmation. The texts of the VAT Law, the Executive Regulation, the administrative penalties decision and Federal Tax Authority Decision No. 13 of 2026 were read directly from the consolidated publications of the Federal Tax Authority and the Ministry of Finance; Articles 3, 35, 47, 48, 50, 51, 54, 54 bis, 55 and 56 were checked against the text. Customs Notice No. 16/2026 was read from the official Dubai Customs PDF. Registration and declaration fees were checked against the Dubai Customs Service Guide 2025, version 9. The Designated Zones list is taken from the Federal Tax Authority’s consolidated publication — the gazetted texts of Cabinet Decision No. 59 of 2017 and of all five amending decisions are absent from the accessible official resources, and the zone names should not be presented as quotations from the decisions themselves. The Common Customs Law of the GCC States and its Rules of Implementation were read in the consolidated text published by the GCC Secretariat General, and the valuation and suspension provisions cited here come from it. The GCC Unified Customs Tariff schedule, by contrast, could not be obtained as a standalone document: the alcohol rate is therefore cited from the government portal without confirmation from a tariff line, and the AED 3,000 traveller allowance from the Passenger Customs Guide, the figure itself sitting in the Rules of Implementation rather than in Article 103. The scope, qualifying goods and legal basis of the industrial customs exemption could not be confirmed from a primary source and are not described here. No limitation period for reclaiming overpaid customs duty is established in Dubai Customs’ published services and policies, and none is stated here. It could not be confirmed from a live Federal Tax Authority page that the VAT301 form exists in EmaraTax in 2026 in its earlier form; what is described is the mechanism in the Executive Regulation, not the interface.

Disclaimer

This material is provided for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before acting on any of it, obtain individual professional advice reflecting your specific circumstances, jurisdiction, corporate status and current regulatory requirements.

Position stated as at: August 2026.