What changed?
The 2024 and 2025 VAT amendments were already effective, but the FTA had not yet consolidated these practical interpretations in VATP046.
VATP046 does not introduce new legislation. It publishes the FTA's official interpretation of the amended provisions, including fixed-establishment, e-invoicing, reverse-charge, excess-VAT and input-tax due-diligence points.
Practical consequence: Businesses should revisit UAE presence, electronic invoicing controls, imported-supply documentation, VAT-credit ageing and input-tax due diligence against the clarified administrative position.
Confirmed facts
The UAE Federal Tax Authority issued VAT Public Clarification VATP046 on 4 September 2026. The document explains amendments made to Federal Decree-Law No. 8 of 2017 by Federal Decree-Law No. 16 of 2024 and Federal Decree-Law No. 16 of 2025.
VATP046 is interpretive guidance. It does not itself amend the VAT legislation. The FTA states that the 2024 amendments took effect on 30 October 2024 and the 2025 amendments took effect on 1 January 2026.
What changed
On fixed establishment, the FTA explains that a foreign business can be treated as having a UAE Fixed Establishment even if it does not own the premises. Its example is a foreign business whose employees regularly work from a client's UAE premises and use technology resources such as phones or computers in the UAE.
On e-invoicing, VATP046 confirms that an Electronic Invoice is not automatically a Tax Invoice unless the Executive Regulation requirements are also met. Where the Electronic Invoicing System applies, registrants must issue and transmit Tax Invoices and Tax Credit Notes electronically, and a Taxable Person must retain the relevant Tax Invoice in electronic-invoice format where required or issued under the system in order to recover related Input Tax.