Thursday, 02 November 2023 / Published in VAT

The Big VAT Shift: Electronics Wholesalers in UAE Brace for New B2B Rules

Starting October 30, 2023, the UAE electronics sector shifted to the ‘Reverse Charge Mechanism‘ for VAT on B2B supplies of electronics and tech devices meant for resale or further manufacturing. The UAE has also issued specific criteria for classifying electronic device components, which are eligible for the Reverse Charge Mechanism.


Key Points:

  • UAE electronics industry adopted the ‘Reverse Charge Mechanism’ for VAT on B2B supplies of electronics.
  • Eligible components for the Reverse Charge Mechanism include those used in manufacturing, necessary for device operation, or replacements.
  • Components enhancing device functionality but not essential for operation are not covered.
  • SIM cards and similar external cards are exempt.
  • Failure to declare intent of use can lead to unrecoverable VAT for buyers.
  • Correct classification is crucial to avoid VAT-related risks.
  • Transitional provisions apply to supplies dated October 30, 2023, or later.
  • Compliance with date of supply rules, declarations, and TRN verification is necessary.
  • Industry and business owners should ask the right questions to ensure compliance.

The UAE electronics sector transitioned to the ‘Reverse Charge Mechanism’ for VAT on B2B deals involving devices intended for resale or further manufacture on October 30, 2023. A ministerial decision outlined the criteria for eligible electronic device parts, including those used for manufacturing, operation, or replacement. However, components that enhance device functionality but aren’t necessary for operation aren’t covered. SIM cards and similar items are also excluded.

The Reverse Charge Mechanism for B2B supplies is mandatory, and failing to declare intent of use may render input VAT non-recoverable. VAT-registered buyers aiming to resell/manufacture must ensure VAT isn’t charged on electronic device supplies. Proper classification is crucial, as misclassifying items can lead to VAT credit loss or penalties for suppliers.

Certain items like earphones, external storage devices, and protective covers enhance device enjoyment but won’t qualify as parts and pieces. Memory cards, monitors, and motherboards, necessary for device operation, likely will qualify. Other items require careful assessment.

All electronic device supplies after October 30, 2023, must adhere to VAT treatment and compliance requirements, including transitional provisions for advance payments and written declarations. Businesses must evaluate various tax aspects and ensure they ask the right questions regarding this change.

The information provided herein is for the general information of the user and is provided in good faith. We make no representation or provide warranty of any kind, express or implied, regarding the adequacy, suitability, validity, or completeness of the information. Our advice in regard to UAE corporate tax and value added tax is based on our understanding of the relevant laws and the regulations issued. We cannot be held responsible for new regulations and/or interpretation of existing regulations by the FTA that is not consistent with our advice. Under no circumstance shall we have any liability to any user of this information or to third parties for any loss or damage of any kind incurred as a result of the use or reliance of this information.