If you are VAT-registered in the UAE and you sell to other businesses or to government entities, you are in scope. This applies to mainland and
free zone companies alike.
Your annual revenue determines your phase, not whether you are covered at all. A small consulting firm invoicing AED 800,000 per year has the same obligations as a distributor billing AED 200 million — just six months later.
There are some exemptions:- B2C transactions, exempt until further notice.
- Government transactions carried out in a sovereign capacity.
- Certain international airline services.
- Exempt financial services.
If your business is close to one of these categories — for example, if you are a mixed B2B and B2C retailer or a financial services firm with both exempt and taxable supplies — you should confirm your classification rather than assuming it. While the
VAT treatment of your supplies and your e-invoicing obligations are related, they are not the same issue.