Businesses that receive payment in digital currencies (e.g., Bitcoin, Ethereum, USDT, and other cryptocurrencies) are now required to convert the digital currency value into AED using a specific methodology prescribed by the FTA when reporting VAT.
Why the Directive still matters for exempt supplies: exempt is not outside scope – the AED value must be disclosed in the VAT return and drives input tax apportionment, so a prescribed valuation method is needed even where no output tax arises.
| Activity | VAT treatment | Basis |
|---|---|---|
| Transfer of ownership / conversion of virtual assets (incl. virtual currencies) | Exempt – retroactive to 1 Jan 2018 | Art. 42(2)(k),(l) VAT ER |
| Custody, wallets, platform fees, commissions – for an explicit fee | Taxable at 5% | Art. 42(2)(m),(4) VAT ER |
| Crypto mining – own account / for others for a fee | Outside scope / 5% (0% if qualifying non-resident) | VATP039 |
| Goods or services paid for in digital currency | Normal VAT treatment of the underlying supply | VAT Law; Directive 3/2026 |
For VAT reporting purposes, businesses must follow the following steps:
The Prescribed Conversion Mechanism – Four Steps
Select platforms
Pick three from the FTA approved list; use the same 3 for the whole calendar year – the list as of today:*
Obtain rates
Rate from each platform at the date and time of supply or date of receipt of consideration.
Average
Arithmetic average of the three rates.
Convert to AED
Apply the average rate; disclose the AED value in the VAT return.
*The FTA will issue a Public Clarification for currencies whose rate is not available on three listed platforms and will maintain the published list.
| Transaction 1 – The Customer sells 0.10 BTC via a UAE exchange (1% fee excluding VAT) | Amount (AED) | VAT |
|---|---|---|
Directive 3/2026 valuation – 3 platform average, whereas;
|
1 BTC = 410,000 (Average amount) | – |
| SUPPLY 1 – THE CURRENCY ITSELF: conversion / transfer of 0.10 BTC | ||
| Value of the exempt supply: 0.10 BTC × 410,000 – disclosed in the VAT return | 41,000.00 | Exempt – 41,000 (Art. 42(2)(l)) |
| SUPPLY 2 – THE SERVICE FEE: explicit 1% commission for executing the trade | ||
| Fee: 1% × 41,000 – explicit consideration, so the exemption does not apply | 410.00 | Taxable 5% (Art. 42(4)) |
| Output tax on the fee (reported in the VAT return) | – | 20.50 |
| Directive 3/2026 valuation |
3 platform average, whereas;
|
| Amount (AED) | 1 BTC = 410,000 (Average amount) |
| VAT | – |
| Description | Value of the exempt supply: 0.10 BTC × 410,000 – disclosed in the VAT return |
| Amount (AED) | 41,000.00 |
| VAT | Exempt – 41,000 (Art. 42(2)(l)) |
| Description | Fee: 1% × 41,000 – explicit consideration, so the exemption does not apply |
| Amount (AED) | 410.00 |
| VAT | Taxable 5% (Art. 42(4)) |
| Output tax on the fee | 20.50 |
Notes: VAT is never charged on the BTC being converted – only on the explicit fee, commission or spread. The AED 41,000 exempt value still matters: it is disclosed in the return and drives input tax apportionment (input VAT attributable to it is generally irrecoverable). Later market-rate movements are accounting exchange differences, not VAT adjustments; rate evidence from all three platforms must be retained.
A consultancy invoicing 0.10 BTC (excl. VAT) for advisory services makes a taxable supply of the service: value AED 41,000 (0.10 × 410,000 average) and output VAT AED 2,050, both stated in AED on the tax invoice, with the AED 43,050 total settled as 0.105 BTC. The 5% attaches to the service, never to the Bitcoin. The client’s transfer of the 0.105 BTC as payment, with the AED 2,050 recoverable as input tax subject to its normal recovery position.
Businesses accepting digital assets can no longer rely on a single exchange or internally determined conversion methodology. A standardized approach is now prescribed by the FTA.
Organizations may need to update:
to automatically capture and calculate exchange rates from the selected exchanges
Given the volatility of cryptocurrencies, the taxable value may vary significantly depending on the precise date and time of supply or payment.
Businesses should ensure robust controls around:
The directive specifically requires taxpayers to retain records evidencing exchange rates obtained from each of the three exchanges. Failure to maintain these records may expose businesses to VAT assessment risks during FTA audits.
Businesses should consider:
This directive provides long-awaited clarity on the VAT treatment of transactions settled in digital currencies, a gap left behind by Cabinet Decision No. 100 of 2024. While the prescribed averaging methodology creates consistency in reporting, it also introduces new compliance, documentation, and system requirements for businesses participating in the digital asset ecosystem.
Organizations accepting cryptocurrency payments should proactively assess the operational and tax implications of the directive and ensure that systems, policies, and controls are updated before the next VAT reporting cycle to mitigate compliance risks and potential disputes with the FTA.