Dubai, UAE: The UAE Federal Tax Authority (FTA) has issued Public Clarification VATP045 – Concerned Goods – Tax Invoices and Input Tax Recovery, bringing fresh clarity to the VAT treatment of historical imports. The clarification was issued on 26 August 2026 and focuses on imported Concerned Goods, tax invoice requirements and Input VAT recovery.
The update is especially relevant for businesses that imported Concerned Goods before the recent VAT rule changes. Under the FTA definition, Concerned Goods are imported goods that would not be exempt from VAT if they were supplied in the UAE.
What VATP045 Means for Historical Imports
The clarification covers Concerned Goods imported on or before 31 December 2025. Under the earlier VAT treatment, an import of Concerned Goods for business purposes was treated as a taxable supply made by the importer to itself. This meant that tax invoicing and VAT accounting requirements applied to the transaction.
VATP045 now provides clarity for businesses reviewing these older transactions. A business that did not issue a self-tax invoice for a historical import does not automatically lose its Input VAT recovery position. The business must still have the relevant supporting records and meet the conditions for Input VAT recovery.
This makes the clarification important for companies that are checking older VAT records, preparing for an FTA review or reconciling import transactions with their VAT returns.
What Changed From 1 January 2026?
Businesses should also separate historical imports from current transactions.
From 1 January 2026, the VAT rules changed regarding the self-invoicing treatment of Concerned Goods. As a result, businesses should not apply the older self-invoicing approach to new imports simply because it was used for earlier transactions.
VATP045 is therefore important mainly because it helps businesses understand the treatment of legacy imports and the records needed for their VAT position.
VATP045 and VATP044 Are Not the Same
Businesses should also avoid confusing VATP045 with the FTA clarification on Concerned Services. Concerned Goods relate to imported physical goods, while Concerned Services cover imported services where the place of supply is in the UAE and the services would not be exempt.
What Should Businesses Do Now?
UAE businesses with historical imports should review their records rather than wait for an FTA review. This includes checking overseas supplier invoices, customs records and VAT return information related to older imports.
Businesses should also check whether their Input VAT claims were supported by the required documents and whether their import figures were correctly reflected in their VAT records. The FTA states that Input VAT recovery depends on meeting the applicable conditions and holding documentation that supports the VAT paid.
Ignoring these checks can leave gaps in a business’s VAT records and may create problems when historical transactions are reviewed.
With its focus on UAE tax and compliance, Dubai Business and Tax Advisors (DBTA) can help businesses review historical VAT records, assess supporting documents and understand their tax compliance position. Professional review can help businesses identify gaps early and keep their VAT records organised for future FTA requirements.
