Comparison between the Amended

Comparison Between the Amended KSA VAT

Implementing Regulations and UAE VAT Regulations

Comparison between the Amended

The amendments/additions to the KSA VAT Implementing Regulations published last June 2023 were compared to UAE VAT Laws and Regulations.

1)   Comparison




Article 8 (8)–  Requirement to display registration certificate on website / electronic stores

No such requirement.

Article 9 (6) – Activities contractually linked with the employer shall not be considered as ‘economic activity’

VDL Article 1 – Activities conducted by a person who is not independent is not considered as a ‘business’

Article 9 (7) – Workers under service secondment contracts will be considered as salaried employees on certain conditions

No similar provision.

Article 29 (7) – Fees and commissions on life insurance contract is exempt from VAT

VATGIN1 4.1.2 – VAT Insurance-related services are subject to VAT at 5%

Article 36 – Supplies of qualified suppliers to diplomatic missions will be subject to 0% VAT

ER VDL Article 69 (1) – VAT is charged to diplomatic missions but may be refunded subject to claim

Article 40 (7) (d) – Submission of other supporting documents for bad debt adjustments

VDL Article 64 (1) – Customer shall be notified of the amount written off

Article 63 –   Limit of correcting errors in subsequent VAT returns has been increased to SAR 15,000

ER TPL Article 10 – Limit of correcting errors in subsequent VAT returns is at AED 10,000

Article 75 (5) – Opinion or ruling is binding on the Authority or Taxable Person

TPGPC1 8 – Clarifications are not subject to the dispute resolution process


VDL – VAT Decree Law

ER VDL – Executive Regulations of VAT Decree Law

ER TPL – Executive Regulations of Tax Procedures Law


2)   Key Takeaways

  • Taxpayers shall re-assess their current VAT position and practices.
  • Seek the help of professionals to ascertain how amendments will impact businesses.

Contact Us

Markus Susilo
Markus Susilo
Partner- Payroll and Indirect Tax
Michel Ruitenberg
  Partner DIFC - Indirect Taxes