The text as written
Chapter 6.3.2 first fixes the rule: business transactions "carried out between members of the same VAT group fall within scope and are not excluded solely by reason of being intra-group". It then gives the practical reason for the grace period: these transactions are numerous and recurring, with complex internal pricing and settlement, often processed through centralised accounting systems and automated intercompany charging — so they need more time to ensure data consistency and reporting integrity.
"To support implementation readiness for VAT groups, a temporary grace period will be provided in respect of intra-group transactions. The grace period will apply to Business Transactions carried out between members of the same VAT group for a period of twenty-four (24) months commencing on 01 January 2027."
Then the sentence that governs everything: "The grace period affects the timing of compliance only. It does not remove intra-group transactions from the scope of the Electronic Invoicing System and does not affect the application of Electronic Invoicing obligations to other Business Transactions carried out by the Person."
What the grace period covers and what it does not
| Transaction | Covered? |
|---|---|
| Company A sells to Company B, both members of the same VAT group | Yes — until 1 January 2029 |
| Company A recharges shared staff costs to Company B (same group) | Yes — an intra-group transaction |
| Company A sells to sister Company C, commonly owned but not a member of the VAT group | No — an ordinary B2B transaction on its normal date |
| The group sells to customers or buys from suppliers | No — the normal date by revenue tier |
| A holding company (outside the VAT group) charges management fees to subsidiaries | No — chapter 6.3.1 treats it as an in-scope business transaction |
The threshold calculation does not change
The grace period does not deduct intra-group transactions from your revenue for the AED 50 million threshold. Your tier (1 January or 1 July 2027) follows Decision 244 and its revenue definitions, not the guidelines. A group whose consolidated revenue exceeds the threshold complies from 1 January 2027 for all its external transactions.
Three planning questions for groups
- One provider for the group or one per member? The guidelines require one provider "per Person". In a VAT group, the members are several persons under one tax registration. Ask your provider how it handles multiple Peppol identifiers under one TRN and how it separates each member's reporting, and get a written opinion from your adviser on the EmaraTax registration.
- Do you benefit from the grace period at all? If your central accounting system already produces intercompany charges automatically with the same data, switching e-invoicing on for them from day one may be easier than running two parallel paths for two years. The grace period is a right, not a duty.
- What happens when membership changes? A member joining or leaving the group flips its transactions from intra-group to external, or back, from the date of change. Document the dates — the electronic invoice carries its issue date and is judged by it.