Can I Send an Invoice If I'm Not VAT Registered in the UAE?

Quick answers

Can I send an invoice without VAT registration in the UAE?

Yes — you can issue invoices in the UAE without being VAT registered, but you must not add 5% VAT to your prices and you must not label the document a tax invoice.

When does registration become mandatory?

Registration is mandatory once your taxable supplies and imports exceed AED 375,000 over the previous 12 months, or are expected to exceed it in the coming 30 days.

What should an unregistered invoice contain?

An ordinary commercial invoice should carry: the word "Invoice", a sequential invoice number, the issue date, your business name and address, your client's name, a description of the goods or services, quantities and unit prices, and the total in AED. No TRN. No VAT line.

What do I tell a client who asks for a TRN?

You are not VAT registered, so there is no TRN, and no VAT was charged on this invoice. Because no VAT was charged, there is nothing for them to reclaim. This is normal and it does not make your invoice invalid.

Is this tax advice?

No. This is general information about invoicing without VAT registration in the UAE. Confirm your obligations with the Federal Tax Authority or a qualified tax advisor.

When registration actually becomes mandatory

Registration is mandatory once your taxable supplies and imports exceed AED 375,000 over the previous 12 months, or are expected to exceed it in the coming 30 days.

Voluntary registration is available from AED 187,500. Below that, you cannot register even if you want to.

What you can and cannot do

You can:

• Issue invoices to UAE and international clients
• Charge whatever your services are worth
• Number your invoices sequentially and keep records
• Get paid by bank transfer, card or cash

You cannot:

• Add 5% VAT to your prices
• Show a VAT line or a VAT amount on the invoice
• Put a TRN on the invoice — you don't have one
• Head the document "Tax Invoice"

The last point is the one businesses get wrong. "Tax invoice" is a defined document type for VAT-registered businesses. If you are not registered, what you issue is an ordinary commercial invoice.

What your invoice should contain instead

An ordinary commercial invoice should carry:

• The word "Invoice"
• A sequential invoice number
• The issue date
• Your business name and address
• Your client's name
• A description of the goods or services
• Quantities and unit prices
• The total in AED

No TRN. No VAT line. Nothing else is required, and adding a fake or borrowed TRN is a serious problem, not a shortcut.

What to tell a client who asks for a TRN

Some clients — especially larger companies — will ask for a "TRN invoice" out of habit, because their accounts team wants to reclaim input VAT.

The honest answer is short: you are not VAT registered, so there is no TRN, and no VAT was charged on this invoice. Because no VAT was charged, there is nothing for them to reclaim. This is normal and it does not make your invoice invalid.

If they insist, they are asking you to charge VAT you are not entitled to collect. Don't.

What changes when you register

Once you register and receive your TRN, three things change from that date:

1. You start adding 5% VAT to taxable supplies.
2. Your invoices become tax invoices, headed as such, with your TRN on every one.
3. You start filing VAT returns.

Invoices you issued before registration stay as they were. You do not go back and reissue them with a TRN.

In Fatura Go this is a single setting: invoices are issued without a TRN until you add one, and switch to the FTA tax-invoice format automatically once you do.

Frequently asked questions