The table as in chapter 10.1
| Type | Standard billing | Self-billing |
|---|---|---|
| Tax Invoice | 1. Electronic Tax Invoice | 1. Self-billed electronic Tax Invoice |
| Tax Credit Note | 2. Electronic Tax Credit Note | 2. Self-billed electronic Tax Credit Note |
| Invoice | 3. Commercial Invoice | Not applicable |
| Credit note | 4. Electronic Credit Note | Not applicable |
In XML the type sits in cbc:InvoiceTypeCode: 380 for an invoice and 381 for a credit note, with further fields distinguishing tax from commercial and self-billed from standard, per the PINT AE specification.
The Commercial Invoice: for whom?
"Commercial Invoice" is the guidelines' term for an invoice issued for sales that do not require a Tax Invoice under the VAT law: exempt or out-of-scope supplies, or supplies by persons not registered for VAT. The new rule: "traditional (e.g. pdf or paper format) Commercial Invoices must be replaced by Electronic Invoices that meet specific criteria and are exchanged and reported via the model described in Chapter 5". Meaning: a business under the VAT registration threshold (AED 375,000) that sells to companies needs an accredited provider and issues electronic Commercial Invoices on its date.
E-invoicing does not abolish the Tax Invoice — it sets its form
Chapter 6.2 clarifies: "Electronic Invoicing does not remove a Taxable Person's obligation to issue a Tax Invoice or a Tax Credit Note. However, in accordance with Article 65(5) of the VAT Decree-Law, a Person subject to the Electronic Invoicing system will be required to issue a Tax Invoice or Tax Credit Note in the form of an Electronic Invoice or an Electronic Credit Note." It adds a practical point for the transition: since the electronic invoice is XML, a customer not yet on the system may ask you for a non-electronic tax or commercial invoice (to recover input tax, say, or for a corporate-tax deduction). Most providers generate a readable PDF for this; ask about it.
Self-billing: three conditions
Under self-billing the buyer issues the invoice on the supplier's behalf by agreement (common in commissions, purchases from small producers, and some distribution contracts). Chapter 10.3 sets the conditions:
- The buyer is on the system. "The self-billing of electronic Tax Invoices will require the buyer to be on the Electronic Invoicing System." If you are a large supplier complying from January 2027 and the customer who self-bills for you is in the second tier (July 2027), you have a six-month gap to resolve: either they join voluntarily, or you go back to issuing your own invoices.
- VAT-registered only. Self-billing is a VAT arrangement under the Decree-Law, so there is no self-billing of Commercial Invoices and none for an unregistered supplier.
- It covers every transaction. "Once a supplier is in scope for mandatory Electronic Invoicing as per the roll-out plan, this will extend to all Business Transactions, including those that are made under a self-billing arrangement." Review your contracts.
And remember the footnote to chapter 5.2: under self-billing, the compliance obligation moves to the buyer.
Three small rules that prevent rejections
- No provisional invoices. Issue an electronic invoice for the estimated amount and correct it with a credit note (381) or an additional invoice. An electronic invoice is not edited after transmission.
- Partial credit notes are allowed (chapter 10.5, scenario 4), and one credit note may reference several preceding invoices (scenario 3).
- No fields of your own (scenario 25): adding optional fields outside the specification is not allowed. Whatever notes you need go into IBT-22.