Quick answer: VAT on exports in the UAE is 0%, but only when your sale meets the conditions in Article 30 (goods) or Article 31 (services) of the VAT Executive Regulation and you can prove it. Goods must leave the UAE within 90 days of the supply, backed by the right export documents. Services must go to a recipient outside the UAE and must not relate to UAE real estate or to moveable goods located here. If any condition fails, the sale is standard-rated at 5%.
A question we hear from exporters and service businesses alike goes something like this: “My customer is overseas, so I charge 0%, right?” Sometimes, yes. But the rule has conditions, the conditions have paperwork, and the paperwork has a deadline. If one of them fails, the sale is standard-rated, and the 5% becomes your cost to carry, often on an invoice you already sent at 0%.
Here is how the rules work in 2026, including a change to the export documents that many articles still get wrong.
Why the Zero Rate Matters More Than It Sounds
Zero-rated, exempt and standard-rated supplies look similar on an invoice, but they behave very differently in your accounts.
| Treatment | VAT charged to customer | Can you recover VAT on your costs? |
|---|---|---|
| Zero-rated | 0% | Yes |
| Exempt | None | No |
| Standard-rated | 5% | Yes |
| Out of scope | None | Generally no |
Say you spent AED 600,000 on costs in a quarter, carrying AED 30,000 of input VAT. If your sales are zero-rated exports, you claim that AED 30,000 back. If the same sales were exempt, it becomes a real, unrecoverable cost. That difference is why zero-rated claims get scrutiny, and why the label on your invoice deserves care.
Exports of Goods: The Article 30 Conditions
Under Article 45 of Federal Decree-Law No. 8 of 2017, and the conditions in Article 30 of the Executive Regulation (Cabinet Decision No. 52 of 2017), a sale of goods can be zero-rated when:
- The goods physically leave the UAE within 90 days of the date of supply, or are placed under a customs suspension regime under the GCC Common Customs Law
- You hold export evidence that identifies the goods and the destination
- The destination is outside the GCC states that apply VAT
If the goods stay past 90 days, or the evidence is missing, the supply becomes standard-rated and 5% VAT is due.
What counts as evidence for exports after 15 November 2024
This is the part many articles still get wrong. Cabinet Decision No. 100 of 2024, effective 15 November 2024 and explained in FTA Public Clarification VATP040, changed what an exporter must keep. Exit certificates from customs are no longer required. You now need one of these three combinations:
| Option | What you keep |
|---|---|
| 1 | A customs declaration plus commercial evidence, such as an airway bill or bill of lading from the transport company |
| 2 | A shipping certificate plus official evidence, such as an export or clearance certificate from customs, or a certified document from the destination country showing entry |
| 3 | A customs declaration proving the goods were placed under customs suspension |
Exports made before 15 November 2024 stay under the older rules. If an article tells you that you always need both official and commercial evidence, check when it was written. The FTA can also reject documents that do not adequately prove the goods left the UAE, so quality of paperwork still matters.
Indirect exports and the 90-day extension
In an indirect export, the overseas customer or their agent collects the goods and arranges shipping. The customer or agent has to obtain the export documents and pass you a copy. Make that a written term of the sale, with a deadline, rather than relying on goodwill.
If circumstances beyond both parties’ control prevent export within 90 days, or the nature of the supply makes 90 days impracticable, you can apply to the FTA in writing for more time. Do it before the deadline passes, not after.
Exports of Services: The Article 31 Conditions
Services are zero-rated more narrowly than many exporters assume. In general, all of these need to be true:
- The recipient has no place of residence in the UAE, and is outside the UAE when the service is performed
- The service does not relate to real estate located in the UAE
- Since the 2024 amendment, the service also does not relate to moveable goods physically located in the UAE
The FTA looks at how many days a non-resident recipient spends in the UAE over a rolling 12-month period when deciding whether they count as being outside the UAE. Some guidance also refers to residence in other GCC states that apply VAT, so check the current wording of Article 31 before relying on it for a GCC customer.
| Situation | Likely treatment |
|---|---|
| UAE software firm builds an app for a Singapore client with no UAE presence | Zero-rated |
| UAE consultant advises a UK company on its UK product launch | Zero-rated |
| UAE engineering firm advises on a warehouse in Dubai for a German client | 5%, relates to UAE real estate |
| UAE firm repairs equipment located in the UAE for an overseas owner | 5%, relates to moveable goods in the UAE |
The Traps That Turn a Zero-Rated Sale Into a 5% Sale
| Trap | What happens |
|---|---|
| Your customer is a company in a UAE free zone | Not an export. It is a UAE customer, so 5% applies |
| Goods are delivered into a designated zone | Not an export under Article 30(3) |
| Services connected with a designated zone | Generally treated as supplied in the UAE. Designated zone treatment mainly helps with goods |
| Goods still in the UAE after 90 days with no approved extension | 5% is due |
| Export evidence missing or incomplete | 5% is due |
| Customer in a GCC state that applies VAT | Separate rules apply, so do not assume 0% |
| Registering for VAT | Zero-rated sales still count toward the AED 375,000 mandatory registration threshold |
That last point surprises people. A business with AED 900,000 of correctly zero-rated exports is still making taxable supplies and still has to register. Zero-rated is a rate, not an exemption from the system.
The Export Evidence Routine Most Businesses Skip
Most exporters lose the zero rate through admin, not through the law. The airway bill sits in the logistics manager’s inbox while the accountant files the return, and nobody notices the gap until the FTA asks. A simple routine closes that gap:
- Keep one evidence file per zero-rated invoice, named by invoice number, holding the customs declaration, transport documents and any shipping certificate.
- Run a simple tracker with the supply date, the day-90 deadline, the date evidence arrived and a status. Chase anything still open at day 60.
- Put document deadlines into your sales terms for indirect exports, so the customer or agent knows when copies are due.
- Reconcile monthly. Compare zero-rated sales in your ledger with the evidence file, the money received and the figure you are about to report. Our guide to account reconciliation for UAE businesses covers the wider habit.
- Keep everything for at least five years.
This is bookkeeping discipline more than tax expertise. A business with an evidence file behind every zero-rated invoice can answer an FTA query in an afternoon. One without it may end up paying 5% on sales it already closed at 0%.
Invoicing Zero-Rated Exports and E-Invoicing
A zero-rated export invoice should show 0% and be clearly marked as zero-rated. When e-invoicing applies to your business, it also has to carry the right VAT category code. Zero-rated exports use code Z, not E for exempt and not O for out of scope. Because invoice data will reach the FTA in near real time, a wrong code stands out. Our guide to the UAE e-invoicing deadline covers who is in scope and when.
If you sell online to overseas customers, our guide to VAT on e-commerce sales in the UAE covers place of supply and marketplace rules, which sit alongside the export rules here.
What to Do Now
- List your overseas sales from the last year and mark which ones you zero-rated
- For goods, confirm each has one of the three evidence combinations on file, and that shipping happened within 90 days
- For services, confirm each customer is genuinely outside the UAE and that the work is not tied to UAE property or goods
- Check any customer in a UAE free zone, they are not export customers
- Set up the evidence file and tracker before your next return
Getting Your Export VAT Position Checked
If you zero-rate sales and are not certain the evidence would hold up, it is much cheaper to find out now than during an FTA review. Get in touch with our team and we will review your zero-rated sales, or include this as part of a VAT compliance review.
For the FTA’s own explanation of designated zones and how VAT applies inside them, see the FTA Designated Zones VAT Guide.
Frequently Asked Questions
Are exports zero-rated in the UAE? Usually, but not automatically. Goods must leave the UAE within 90 days of the supply with the right evidence on file, and services must meet the Article 31 conditions. If either test fails, 5% VAT applies.
How long do I have to export goods to keep the 0% rate? 90 days from the date of supply. The FTA can extend this on written application, but only where circumstances beyond both parties’ control prevented export, or where the nature of the supply makes 90 days impracticable.
What documents prove an export after November 2024? One of three combinations: a customs declaration plus commercial evidence, a shipping certificate plus official evidence, or a customs declaration proving customs suspension. Exit certificates are no longer required for exports made from 15 November 2024.
Is a service to a client in a UAE free zone an export? No. A company in a UAE free zone is a UAE customer for VAT purposes, so the service is generally standard-rated at 5%.
Do zero-rated sales count toward the AED 375,000 VAT registration threshold? Yes. Zero-rated supplies are taxable supplies, so they count toward the mandatory registration threshold.
Where do I report zero-rated exports on my VAT return? In the zero-rated supplies section of Form VAT201, separate from exempt supplies. Confirm the exact box on the current form in EmaraTax before filing.
