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Invoicing being a key function of every business and e-invoicing is a norm related to it, it is super critical for businesses to understand the concept of e-invoicing and the preparedness that allow you to adapt to the new system of issuing of invoices.

e-invoicing is a process through which business to business (B2B) transactions are authenticated with a unique number known as IRN and QR code by the invoice registration portal (IRP). Read What is e-Invoice in GST? to know more.

What e-invoicing requires?

In the e-invoice system, as a supplier, the moment you create an invoice for your customer, it should be uploaded to IRP where the validation will be done, and IRN along with the QR code will be issued. Next, you need to print the invoice with QR code before issuing it to your buyer.

How is current practice different from e-invoicing?

There is a drastic change if you compare the new norm with the current practice which doesn’t require you to authenticate the invoice. In current practice, as a supplier, you print the invoices, issue it to the buyer and then periodically report the details in GSTR 1. Post that, the buyer gets the visibility of invoices in GSTR -2A.

The other mandate that comes with e-invoicing is that an invoice is valid only if the invoice is authenticated by IRP and the QR code (which is embedded with an IRN) is printed on the invoice. In another way, any invoice without QR code that is authenticated by IRP will remain invalid. This implies that the buyer will be eligible for input tax credit only on the invoices that are authenticated by the IRP portal.

The change and the technology

The new mandate requires you to upload the e-invoice details in prescribed format (JSON) to IRP. Next, download the output file (JSON) that is authenticated by IRP with IRN and QR code. Later, you need to print QR code and IRN on the invoices before issuing it to the buyer.

As a result, the current practice of invoicing will change. First, businesses need to make a provision for real-time upload of invoice data and printing of QR code. This will emphasize the necessity of businesses to have a right technology which assists in real-time and instant generation of e-invoices without need to change the invoicing process.

Secondly, the business behaviour is expected to change where the buyer will drive the supplier to upload the invoices to the government system to confirm his eligible ITC. Therefore, it is evident that buyers will appreciate doing business with the suppliers who recognise the importance of quick and accurate upload of invoices.

Businesses who are using software that directly integrates with the IRP portal will find it easy to manage the e-invoicing requirements. Because the direct integration helps you automatically upload the e-invoice data to the portal and instantly print the QR code into the invoices. This way, you can continue the invoicing process as always without the need to change.

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Introduction to VAT Registration in UAE

Being registered under the VAT law means that a business is acknowledged by the government, as a supplier of Goods and Services and is authorized to collect VAT from customers and remit the same to the government. Only VAT registered businesses will be allowed to do the following:

• Charge VAT on taxable supply of goods and services
• Claim Input Tax Credit on VAT paid on their purchases, which will be deducted from VAT liability on sales
• Payment of VAT to the government
• Periodic filing of VAT return

Apart from the above, all registered businesses have to align their business reporting structure in line with the compliance requirements such as accurate and updated books of accounts, tax paid documents such as Tax invoice, credit notes, debit notes, records to all inward supplies and outward supplies etc. are required to be maintained.

Therefore, understanding the fundamentals of VAT will be one of the important steps for your VAT preparation and obtaining VAT registration will be the first step towards transiting your businesses to the VAT era.

Who should register under VAT?

Are all businesses liable to register under VAT? No, only those businesses crossing the defined annual aggregate turnover threshold are liable to register under VAT. Based on the registration threshold, a business will either be mandated to register or as an option, a business can apply for registration or can seek exemption from VAT registration

On this basis, VAT registration in UAE can be classified into the following:

• Mandatory VAT Registration
• Voluntary VAT Registration
• Exemption from VAT Registration

VAT registration Deadlines in UAE

As a move towards implementation of VAT in UAE on 1st January 2018, the Federal Tax Authority (FTA) is inviting applications for VAT registration. The FTA has opened its portal to allow the businesses to register online. The early call for online registration allows the businesses to be prepared well in advance and be ready to charge VAT from 1st January 2018. The UAE VAT registration in the FTA portal is carried out in a phased manner depending on the turnover of the business.

VAT Turnover Calculation for Registration in UAE

In UAE VAT, businesses whose annual turnover exceeds the mandatory registration threshold of AED 375,000 and the voluntary registration threshold of AED 187,500 are allowed to apply for VAT registration. Therefore, it is crucial for businesses to understand what type of supplies are considered in deriving the annual supplies turnover and how to calculate the VAT turnover for registration in UAE.

How to Apply for VAT Registration in UAE

In UAE, the businesses whose turnover exceeds AED 375,000 have to mandatorily apply for VAT registration. To facilitate the businesses to register, the Federal Tax Authority (FTA) has opened its portal for online VAT registration. The deadlines based on the turnover of businesses are already announced by FTA and the registration will be carried out in a phased manner. While it is crucial for businesses to determine their obligation towards VAT registration, it is also important for businesses to know how to apply for VAT Registration and understand the level of details required to complete the online registration process.

This is because, before applying or starting the online VAT registration process, having a good understanding about the type of details required and steps to complete the online VAT registration will help you to prepare well in advance. As a result, the registration process can be completed easily and can avoid unnecessary delays due to furnishing of incorrect details which could even lead to rejection of registration application.

• Creation of e-Service Account
• Login to your e-Service Account
• VAT Registration Form: The online VAT registration form contains 8 sections as shown below, in under which the details need to be furnished for completing VAT registration
  • About the applicant
  • Details of the applicant
  • Contact details
  • Banking details
  • Business relationships
  • About the VAT registration
  • Declaration
  • Review & submit

VAT Group Registration

In UAE VAT, any person conducting business is not allowed to have more than one Tax Registration Number (TRN), unless otherwise prescribed in the UAE Executive Regulation. Thus, even if you are operating via branches in more than one Emirate, only one VAT registration is required. With a similar objective, if two or more persons are related or associated parties in the businesses, they are allowed to apply for VAT group registration.

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To determine whether the value of supplies has exceeded the mandatory registration threshold limit or the voluntary registration threshold limit, the following needs to be considered.

• The value of taxable supply of Goods and Services: Taxable supplies refers to all the supplies of goods and services made in UAE on which VAT is levied at the standard rate of 5% including zero-rated supplies. This does not include the notified supplies which are exempted from VAT.
• The value of reverse charge Supplies: Reverse charge supplies are those notified supplies on which the recipient or the buyer are required to pay the VAT to the government unlike forwarding charge, where the supplier will collect VAT from the buyer and pay. The value of such supplies needs to be considered in arriving at the turnover threshold for VAT registration.
• Imports: The value of taxable goods and services imported on which the importer is liable to pay tax.

Let us understand how to calculate the VAT Turnover threshold with an example

Rose General Stores is a supermarket in UAE, engaged in supply of groceries and all types of household products. They also import certain home furnishing products from other countries and supply it to the customers in UAE as well as export it to other countries. The following are the different types of supplies made by Rose General Stores.

To determine Rose General Trader’s eligibility for registration in UAE, taxable supplies + exports (zero-rated supplies) + imports + reverse charge supplies should be considered. Exempt supplies will not be considered in arriving at the registration threshold. The registration threshold calculation of Rose General Trader is given below:

The turnover of Rose General Stores for VAT registration is AED 625,000 which has exceeded the mandatory registration threshold of AED 375,000. Thus, Rose General Stores is required to mandatorily register under UAE VAT.

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Mandatory VAT Registration in UAE

All the businesses who have a place of residence in the state of UAE and whose value of supplies in the member states in previous 12 months has exceeded AED 375,000 should mandatorily register under UAE VAT. Also, if the businesses anticipate that the total value of supplies will exceed the mandatory registration threshold of AED 375,000 in the next 30 days, then they too will have to register under UAE VAT.

Those businesses, who do not have a place of residence in the state of UAE, will have to compulsorily register under VAT irrespective of the registration threshold.

Voluntary VAT Registration in UAE

All the businesses having a place of residence in the state of UAE who are not required to mandatorily register under VAT, are given an option to voluntarily apply for registration. This can be done, only if the annual supplies or taxable expenses incurred is not less than voluntary registration threshold. The Voluntary Registration Threshold is AED 187,500 which is 50% of the mandatory registration threshold.

Here, the registrations are not mandatory, it is optional for business to decide whether they would want to register. The inclusion of taxable expenses as criteria to determine the eligibility for voluntary registration provides an opportunity for all the start-up business to register under UAE VAT. This is because, as a start-up, the turnover or value of supplies may be lesser but there is a high possibility that huge amount of taxable expenses would have been incurred in starting the business or during the initial stage of the business. As a result, the inclusion of taxable expenses as a criteria for voluntary registration would enable all the start-up business to register with zero turnover.

VAT Registration Exemption

The businesses whose value of supplies in the member states is below the voluntary registration threshold of AED 187,500 are not allowed to register under UAE VAT. Also, the businesses who are engaged in making only zero-rated supplies may request for VAT registration exemptions.

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