1. One provider only — for sending and receiving
Chapter 6.1 is explicit: a person in scope "must appoint only one ASP" covering both sending (accounts receivable) and receiving (accounts payable). You cannot pick a cheap provider for sending and another to receive your suppliers' invoices. So "do you receive incoming invoices, and how do you show them to me?" is now a selection question, not an add-on.
2. E-invoicing does not depend on VAT registration
The scope is "all Persons who make a Business Transaction in the UAE, notwithstanding their VAT registration status". A business that is not VAT-registered issues an electronic "Commercial Invoice" instead of a Tax Invoice. The familiar figure of 450,000 VAT-registered businesses is a floor, not a ceiling.
3. Storage: 5 years, 7 for real estate, and cloud outside the UAE is acceptable with conditions
Chapter 5.4 sets the retention periods: 5 years after the tax period for a taxable person, 5 years from year-end for others, 7 years for real-estate records — plus 4 more years in a dispute, an audit, or after notice of an audit. The phrase "within the State" in Article 11 of Decision 243 is read flexibly: a business complies if records sit in an electronic system that preserves their integrity, the storage infrastructure — inside or outside the UAE — lets it produce the records promptly on request, and the FTA can retrieve them complete and readable. Details in the storage article.
4. VAT groups: 24 months for intra-group transactions
Chapter 6.3.2 grants a 24-month grace period from 1 January 2027 for transactions between members of the same VAT group. It defers timing only; those transactions remain in scope. The full explanation is in the VAT-groups article.
5. An advance is invoiced when received; the final invoice covers only the balance
Appendix 5 (new in 1.1) settles an old argument in contracting, real estate and services: on receiving an advance you issue an electronic Tax Invoice immediately (type 380); on completion the final invoice is for the remaining amount only, referencing the advance invoice in the reference fields (IBT-25/26) or a note (IBT-22). Under retention arrangements you invoice the amount payable after deducting the retention, then a separate invoice for the retained amount when it falls due. A worked example is in the advance-payments article.
6. Non-residents e-invoice too
Chapter 6.3.3: a person with no place of residence in the UAE who is obliged to issue Tax Invoices under the VAT law issues them as electronic invoices. If you deal with a foreign supplier that is VAT-registered in the UAE, its invoice to you will arrive through the system.
7. No QR code, no barcode
Chapter 5.3: an electronic invoice is issued, transmitted and received in XML "and will not feature a QR code or barcode". If you designed your invoice template around a Saudi- or Egyptian-style QR, think again. The value is in the structured data, not the printout.
8. Holding companies and the excluded transactions
A holding company with purely passive income is out of scope — but any recharge of costs (management fees, say) to a third party or a related company is a business transaction and brings it in. The explicit exclusions are three: sovereign activities of government entities, international air passenger tickets and air waybills (24 months), and exempt financial services. See the exclusions article.
And the 28 special scenarios?
Chapter 10.5 lists 28 scenarios with their fields: line- and invoice-level discounts, volume discounts by credit note, rounding to two decimals at total level, multiple payment methods and dates, foreign-currency invoices with the exchange rate and VAT in AED, import VAT paid by an agent, and HSN codes as optional for now. You do not need to memorise them — you need to ask your provider: "which of the 28 apply to my invoices, and how does your system fill their fields?"