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Book Your Free ConsultationThe United Arab Emirates (UAE) has long attracted bullion traders, luxury retailers, and foreign businesses seeking a stable hub for international transport of high-value taxable goods. Its economic agreements with other GCC countries, reliable logistics, and high-quality public services create an ideal platform for global commerce. Yet, even in this environment, value added tax (often referred to simply as added tax or general consumption tax) demands close attention. Since its rollout under Federal Decree-Law No. 8 of 2017 (the primary federal decree law governing VAT), the system has undergone several refinements.
The latest watershed is Cabinet Decision No. 127 of 2024, which dramatically expands the reverse charge mechanism (RCM) for precious metals and gemstones. By shifting the liability to the taxable person who buys and resells or further manufactures these high-value items, the new vat law eliminates the need for suppliers to pay VAT up-front, reduces fraud, and bolsters the UAE’s status as a premier luxury-goods marketplace. This guide explains the legislation, the practical tax treatment, and how VAT-registered businesses generally can stay compliant while unlocking cash-flow efficiencies.
Under UAE law, transactions involving gold, diamonds, and other precious goods are treated as taxable supplies, requiring businesses to charge VAT at the standard 5 % rate unless a specific relief applies. As an indirect tax, value added tax operates alongside other levies such as services tax in comparable jurisdictions, shifting the ultimate burden to the consumer while suppliers manage collection and remittance.
It is essential for businesses to adhere to all applicable VAT laws, as compliance is required under the UAE’s legal framework. Official VAT legislation and guidance can be found through government sources such as the Federal Tax Authority.
To remain compliant, VAT‑registered businesses must issue a complete tax invoice for every sale or purchase of bullion, jewellery, or gemstones. Each invoice must show the seller’s TRN, an accurate description of the goods, the consideration exclusive of VAT, and the amount of VAT charged. All invoices should be captured and archived within an auditable e‑invoicing system capable of exporting records to the Federal Tax Authority and supporting the forthcoming real‑time reporting requirements.
Non‑compliance can lead to reassessments, penalties, and reputational harm. Businesses trading in precious goods should therefore review supply‑chain documentation, automate counterparty TRN checks, and maintain rigorous internal controls to ensure every transaction satisfies the UAE’s VAT framework.
UAE VAT is a 5 % vat rate levied on most supplies of goods and services, including indirect tax on transactions spanning real estate, natural gas, and local passenger transport, though those sectors follow specific rules.
Updates to VAT rates can significantly impact the precious metals market, affecting trade, compliance, and market competitiveness in Dubai and the UAE.
Executive regulations issued by the Cabinet and interpretations from the Federal Tax Authority (FTA) flesh out the core vat regulations that stem from the federal law.
The FTA administers tax registration, audits, and refunds through its cloud-based electronic system called EmaraTax. Thanks to automated and electronic processing and a robust e-invoicing system, the FTA now cross-checks every tax invoice, credit note, and tax credit note filed by registered businesses against customs declarations and banking data. This digital oversight reduces errors, accelerates VAT refunds, and deters fraud in highly mobile sectors such as jewellery.
Under the expanded RCM, the buyer records both output tax (VAT due) and input tax (VAT recoverable) for the same tax period, creating a net-zero payment but full visibility for regulators. This approach aligns with global best practice for investment precious metals such as gold, silver, platinum, and palladium at 995 – 999 purity, while extending relief to mixed jewellery pieces that meet the new definition of “Precious Goods.”
The first compliance hurdle is to decide whether an item is a taxable supply of “Precious Goods” or simply a business-related good under ordinary rules. Under Cabinet Decision 127/2024:
Precious metals include gold, silver, platinum, and palladium in raw, semi-finished, or finished form. When purity reaches investment-grade thresholds (e.g., 99.9 % for gold), the metal may also qualify as an investment-grade precious metal eligible for zero-rating.
Precious stones encompass natural or lab-grown diamonds, rubies, sapphires, emeralds, and pearls.
Jewellery like rings, bracelets, luxury watches, where the intrinsic value of precious components exceeds all other materials becomes RCM-eligible.
Non-precious accessories, gold-plated costume items, or watch movements whose engineering outweighs their gemstone value remain standard-rated supplies. Maintaining detailed business records and, where possible, lab assays or blockchain certificates is crucial for demonstrating correct classification. Businesses are legally required to maintain detailed records of all financial transactions to meet VAT compliance obligations.
Under the UAE VAT regime, the treatment of precious metals and gemstones depends heavily on the nature of the transaction and the status of the parties involved. The Federal Tax Authority (FTA) distinguishes between business transactions intended for resale or manufacturing and consumer-facing sales where end-use is clear. This distinction governs whether VAT is charged upfront or handled through the Reverse Charge Mechanism (RCM). Applying the correct VAT treatment is essential not only for compliance but also for maintaining healthy working capital and avoiding penalties.
Where both parties hold a valid TRN, the hallmark of VAT registration and the buyer intends to resell or further process the goods, the invoice must display the RCM statement: “VAT accounted for by the recipient under Cabinet Decision 127/2024.” This avoids cash-flow strain at both ends of the supply chain.
Tourists and other unregistered individuals buying diamond necklaces are charged the full 5 % VAT. Retailers must charge VAT at checkout, issue a compliant structured electronic format invoice via the approved point-of-sale system, and report VAT collected in their returns.
Certain bullion and coins qualify for zero-rating, a niche tax treatment set out in Article 45 of the Decree-Law. Because no VAT is due at all, RCM does not apply. Dealers should be ready to produce certificates proving eligibility to recover VAT on related business expenses (storage, security, insurance).
Buyers may receive a single invoice that bundles an RCM-eligible sapphire pendant with a standard-rated leather box. Item-level coding often enabled by ERP or Fin-Tech modules ensures that each line receives the proper tax flag.
Imports into mainland UAE are self-assessed under the RCM if customs documentation matches the buyer’s declarations. Exports outside the GCC Customs Union are zero-rated, provided that airway bills, bills of lading, and exit certificates prove physical departure.
Under UAE VAT law, businesses with taxable turnover of AED 375,000 or more must register for VAT. Failure to do so can trigger Federal Tax Authority (FTA) assessments of back‑dated tax along with monetary penalties. Companies earning between AED 187,500 and AED 375,000 may opt for voluntary registration; while not compulsory, staying outside the system means they cannot reclaim input VAT or apply the reverse‑charge mechanism on relevant imports and services. Non‑resident suppliers face an even stricter rule: regardless of turnover, they must register immediately, as unregistered status can result in goods being held at customs until compliance is proven.
Every RCM invoice must include the supplier’s and recipient’s TRNs, purity specifications, and an explicit statement that the “person obligated” to report VAT is the buyer.
Reverse-charge supplies slot into Box 3 (supplies) and Box 10 (purchases). Automated upload via the EmaraTax API reduces manual errors and supports voluntary disclosure if corrections are required later.
Seven-year retention applies to ledgers, shipping manifests, financial transactions, and assay reports. Digital archiving ensures easy retrieval and electronic processing during audits.
Persistent failure to meet these obligations may prompt the FTA to suspend the trader’s registration, effectively freezing operations until due tax is paid and deficiencies are rectified.
Proper use of RCM can free millions in working capital:
A dealer turning over AED 60 million monthly avoids pre-funding AED 3 million in VAT. Freed cash can go toward hedging metals on the CME, financing expansion, or lowering prices to win market share.
Refinery fees, security transport, insurance premiums, and education services (staff compliance training) qualify for input VAT recovery, provided they relate to taxable or RCM supplies.
Smelters installing million-dirham furnaces must track those capital assets over 10 years under the Capital Asset Scheme. Changing usage from taxable to exempt supplies triggers an adjustment.
Legitimate VAT refunds on exports are paid directly into traders’ bank accounts, facilitated by EmaraTax’s digitised interface.
Under UAE value added tax rules, specific areas such as DMCC, parts of Jebel Ali, and Ras Al Khaima are treated as outside the VAT territory for precious metals. When VAT‑registered businesses move bullion between these designated zones, the transfer is zero‑rated; intra‑zone B2B sales use the reverse‑charge mechanism. Services delivered inside the zones (e.g., insurance, vault rental, passenger transport) stay standard‑rated unless expressly exempt.
For mainland‑to‑free‑zone transactions, keep export declarations, delivery notes, and arrival confirmations, and issue a compliant tax invoice for each leg. An integrated e‑invoicing system makes it easier to archive these documents and prove, in re‑import cases, that the exact bar or parcel exited and re‑entered unchanged, preserving its VAT history.
Lower financing costs enable technology upgrades such as green smelting of scrap gold, boosting ESG credentials.
RCM avoids “VAT-on-VAT” as gems circulate among cutting, polishing, and setting facilities. Scrap tracking via blockchain helps tax professionals reconcile net weight losses.
Upgrading Microsoft Dynamics, SAP, or Oracle modules to support item-level tax codes, AP automation, and electronic processing ensures quick detection of coding errors which are critical for traders moving hundreds of SKUs daily.
Linking batch IDs to invoice numbers embeds VAT compliance right into the digital provenance chain, making voluntary disclosure easier if a discrepancy surfaces.
In the UAE, output tax is the Value Added Tax (VAT) that VAT-registered businesses must charge on their taxable supplies of goods and services. The standard VAT rate, set by the Federal Tax Authority (FTA), is 5%, and it applies to most taxable goods, including precious metals and jewellery. Registered businesses are responsible for collecting this added tax from their customers and remitting it to the FTA as part of their compliance obligations. Properly managing output tax is essential for businesses to avoid penalties and ensure smooth operations within the framework of UAE VAT regulations.
For VAT-registered businesses, understanding output tax obligations is fundamental to maintaining compliance with UAE VAT regulations. This means charging the correct VAT rate on all taxable supplies, issuing valid tax invoices for every transaction, and keeping comprehensive business records that document each sale. The FTA regularly issues guidance to help registered businesses navigate these requirements, but consulting experienced tax professionals can provide additional assurance that all output tax responsibilities are being met accurately and efficiently.
Calculating output tax involves determining the taxable value of each supply and applying the appropriate VAT rate. VAT-registered businesses must then report their output tax liability in their periodic VAT returns, which are submitted to the FTA. The due tax for each tax period is calculated by subtracting input tax (VAT paid on business purchases and expenses) from output tax (VAT collected on sales). If input tax exceeds output tax, the excess can be carried forward to future tax periods, helping businesses manage their cash flow and VAT obligations more effectively.
The jewellery sector, with its high-value transactions and complex supply chains, faces unique challenges in managing VAT liability. Businesses dealing in precious metals must be especially vigilant in applying the correct VAT rate and adhering to the latest VAT regulations, including those for investment grade precious metals. Staying up to date with FTA guidance and working closely with tax professionals ensures that jewellery businesses remain compliant, minimize their tax liabilities, and take full advantage of available reliefs and credits under the UAE VAT regime.
Credit notes are a vital tool for VAT-registered businesses in the UAE, allowing them to adjust the VAT charged on taxable supplies when necessary. Whether due to product returns, post-sale discounts, or other adjustments, credit notes help registered businesses manage their VAT liability accurately and transparently, in line with FTA requirements.
When goods are returned or discounts are granted after a sale, VAT-registered businesses can issue credit notes to reduce their output tax liability accordingly. Each credit note must be prepared in a structured electronic format and include key details such as the original tax invoice number, the date of issue, and the amount of VAT adjustment. The FTA provides clear guidance on the correct issuance of credit notes, and consulting tax professionals can help ensure that all requirements are met. By following these procedures, registered businesses can maintain accurate VAT records and avoid compliance issues related to taxable supplies.
Penalties for VAT non‑compliance in the precious‑metals and jewellery trade can swiftly erode margins and undermine credibility. If an invoice omits the mandatory reverse‑charge wording, the supplier faces a fine of AED 5,000 per document and becomes liable for the unpaid 5 % VAT plus interest. Using an invalid or suspended Tax Registration Number (TRN) is even costlier, carrying a flat penalty of AED 10,000 and disqualifying the transaction from reverse‑charge treatment, which means the VAT must still be paid in full. Submitting VAT returns late draws an administrative fine of AED 1,000 for a first offence and AED 2,000 for each repeat offence, with interest accruing at 2 % on the first day of delay and 4 % for every subsequent month. The harshest sanction applies to deliberate misclassification of goods. Fines can reach up to 300 % of the under‑declared tax and may escalate to criminal prosecution.
Beyond these monetary penalties, inadequate record‑keeping can stall shipments, freeze letters of credit, and tarnish market reputation. Implementing rigorous “four‑eyes” invoice reviews and automated TRN checks through API integrations is therefore essential to safeguard compliance and avoid costly setbacks.
Navigating UAE value added tax rules in the precious‑metals trade can feel like threading a needle: every invoice, customs declaration, and bullion transfer must align with the Federal Tax Authority’s evolving guidance or profits evaporate into penalties. Young & Right closes that compliance gap by pairing deep sector know‑how with tech‑enabled workflows, so jewellers, refineries, and bullion traders can seize market opportunities while we fortify their VAT position.
For dealers in precious metals and gems, our team maps every SKU to the “Precious Goods” definitions under the UAE VAT law and the relevant Federal Decree Law, structuring contracts so VAT‑registered businesses can maximise zero‑rating and reverse‑charge benefits.
We handle full EmaraTax registration with the Federal Tax Authority, build XML‑ready templates for each tax invoice, and enable real‑time API submissions, all fully aligned with UAE value added tax rules.
Through tailored apportionment plans for mixed supplies, we ensure clients recover legitimate outlays while staying inside the FTA’s framework for value added tax credit.
Our specialists run TRN checks, validate designated‑zone paperwork, and risk‑score large shipments to keep VAT‑registered businesses compliant and competitive.
From ERP tax‑code configuration to blockchain connectors, we audit processes so commercial efficiency meets or exceeds regulatory demand under UAE VAT law.
With end‑to‑end advisory, implementation, and audit defence, Young & Right transforms VAT compliance into a profit driver, helping precious‑metals traders stay ahead in a tightly regulated market.
The expanded reverse charge mechanism under Cabinet Decision No. 127 of 2024 represents the most significant evolution of UAE VAT implementation for precious metals and jewellery since 2017. By shifting liability to buyers, the new rules enhance liquidity, strengthen fraud controls, and reinforce the UAE’s global allure. Traders who fine-tune classification, embed compliant invoicing, and leverage modern electronic processing will not only avoid penalties but also harness tax efficiency for competitive gain.
In the fast-moving world of bullion and luxury jewellery, businesses collect far more than shining assets. They collect obligations. Turning those obligations into opportunities is the hallmark of forward-thinking market leaders, and the updated VAT regime gives them every chance to do just that.
Unlock clarity on Cabinet Decision 127/2024, reverse‑charge requirements, and EmaraTax filing. Partner with Young & Right to turn compliance into a competitive edge.
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