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Key Fact: The UAE has amended its VAT Executive Regulation through Cabinet Decision No. 149 of 2026. Most amendments take effect from 1 October 2026, while certain input-tax apportionment provisions apply from the first tax year beginning after 1 October 2027.
The UAE has introduced another round of changes to its VAT framework, with most of the new provisions taking effect from 1 October 2026. The amendments cover several areas that can affect how VAT-registered businesses record transactions and recover input tax. They also clarify existing provisions, including those on medical products, employee accommodation, and capital assets.
Another change comes later. The standard method for input-tax apportionment has been revised, but the new methodology will apply from the first tax year beginning after 1 October 2027. For businesses, the practical question is simple: which rules apply now, and which ones should you plan for later?
The main amendments introduced through Cabinet Decision No. 149 of 2026 are:
| VAT area | What has changed | When it applies |
| Cash payments | Input-tax recovery may be restricted for qualifying cash-paid supplies above a prescribed threshold | From 1 October 2026 |
| Employee accommodation | Input-tax recovery treatment for employee accommodation has been clarified | From 1 October 2026 |
| Medical products | VAT provisions for the supply and import of medical products have been updated | From 1 October 2026 |
| Input-tax apportionment | The standard apportionment methodology has been revised | From the first tax year beginning after 1 October 2027 |
| Capital Assets Scheme | The scope of the scheme has been clarified | From 1 October 2026 |
| Composite supplies | New rules address when interconnected components can be treated as one composite supply | From 1 October 2026 |
The Ministry of Finance says the amendments are intended to simplify procedures, provide greater clarity for taxable persons and support voluntary compliance.
The amended VAT rules introduce a new restriction on input-tax recovery for certain supplies paid for, or intended to be paid for, in cash.
The important detail is that the value threshold has not been specified in the Cabinet Decision itself. A separate decision by the Minister of Finance will establish the applicable threshold.
Businesses making substantial cash purchases should:
The measure is intended to strengthen compliance and reduce the risk of tax evasion.
Until the separate threshold is issued, businesses should avoid assuming that a particular cash-payment amount automatically prevents input-tax recovery.
The amendments clarify the VAT treatment of employee accommodation for input-tax recovery purposes.
The change matters particularly for employers that provide housing or accommodation as part of their employee arrangements. The amended rules introduce more specific conditions around when related input tax can be recovered.
The FTA has also issued a 2026 decision dealing with cases and conditions for input-tax recovery on employee expenses, so businesses should consider the Executive Regulation together with the relevant FTA requirements.
The VAT provisions covering the supply and import of medical products have been updated to align with the UAE’s revised healthcare legislative framework.
The amendment does not mean that every healthcare or pharmaceutical product automatically receives the same VAT treatment. The applicable classification and conditions still need to be considered under the relevant legislation.
Input-tax apportionment becomes relevant when a business has input tax that cannot be directly attributed entirely to supplies allowing input-tax recovery.
The new rules replace the existing standard input-tax-based method with an output-based approach. Under the revised method, the proportion of recoverable input tax is calculated by reference to the value of supplies.
The revised method will:
The revised provisions do not begin on 1 October 2026. They apply from the first tax year commencing after 1 October 2027.
For a business whose tax year follows January to December, this would generally mean the new method applies from 1 January 2028.
Partially exempt businesses may need to model the effect of the revised calculation before it becomes applicable. That gives finance teams time to review their accounting systems and determine whether existing apportionment procedures need to change.
The amendments clarify the scope of the VAT Capital Assets Scheme.
One notable change is the wording used to define a capital asset. The amended provision focuses on a business asset with a cost rather than referring simply to a single item of business expenditure. The existing AED 5 million threshold and applicable useful-life conditions remain relevant.
The change is a clarification of the framework rather than a reason to reassess every ordinary business expense.
Some transactions contain several components but function commercially as one supply.
The amended VAT rules now provide for a single composite supply where the components are interconnected and the nature and economic substance of the transaction show that they cannot reasonably be separated. The VAT treatment then follows the principal component.
Businesses should therefore look at how the components work together commercially, rather than relying only on separate pricing or invoicing.
There are two main implementation dates to track.
Most of the amendments under Cabinet Decision No. 149 of 2026 take effect.
This includes the changes relating to cash payments, employee accommodation, medical products, composite supplies and the Capital Assets Scheme.
The revised input-tax apportionment provisions apply from the first tax year commencing after this date.
For businesses following a January–December tax year, the revised apportionment methodology would generally begin with the 2028 tax year.
This later date is important. The revised apportionment method should not be treated as an October 2026 requirement simply because the wider VAT amendments take effect then.
There is no need to overhaul every VAT procedure overnight. A targeted review can help identify where the amendments may affect existing processes.

The FTA’s current VAT legislation database includes the amended Executive Regulation and other related 2026 VAT decisions.
The effective date is not the same for every amendment. Finance teams should map each change against the business’s own tax year and transaction profile before updating accounting procedures.
The amendments can affect how businesses handle transactions before those transactions ever reach a VAT return.
A payment method, for example, could become relevant to input-tax recovery where the new cash-payment restriction applies. Similarly, businesses providing employee accommodation may need to revisit their treatment of related expenses.
For businesses selling bundled offerings, the revised composite-supply provision may also require a closer look at contracts, pricing and invoicing arrangements.
The later change to input-tax apportionment is particularly relevant to businesses with residual input tax. Those businesses have more time to prepare, but the change may warrant analysis before the new methodology takes effect.
Arnifi can help businesses review and manage their accounting and VAT processes when UAE tax rules change. Support can include VAT compliance, accounting and recordkeeping, transaction reviews, tax documentation and ongoing tax-related assistance. This can help businesses identify areas that may need to be updated following regulatory changes and keep their financial processes aligned with evolving UAE tax requirements.
Cabinet Decision No. 149 of 2026 amends several provisions of the UAE VAT Executive Regulation. The changes cover cash payments, employee accommodation, medical products, composite supplies, capital assets and input-tax apportionment. Most provisions apply from 1 October 2026, while the revised apportionment provisions take effect later.
Most of the amendments take effect from 1 October 2026. The revised input-tax apportionment provisions apply from the first tax year beginning after 1 October 2027.
The amended rules restrict certain supplies where the consideration is paid, or intended to be paid, in cash above a value that will be specified by the Minister of Finance. The exact threshold has not been established in Cabinet Decision No. 149 itself.
The standard method is changing from an input-tax-based approach to an output-based method linked to the value of supplies. Government entities and charities have a separate methodology under the amended rules. The revised provisions apply from the first tax year commencing after 1 October 2027.
Yes. The amendments clarify the treatment of employee accommodation for input-tax recovery and update VAT provisions concerning the supply and import of medical products. Businesses operating in these areas should review their current treatment against the amended provisions.
The UAE’s 2026 VAT amendments cover several areas of day-to-day tax administration, from cash payments and employee accommodation to composite supplies and capital assets.
Most of the changes take effect on 1 October 2026. The revised input-tax apportionment methodology comes later, applying from the first tax year beginning after 1 October 2027.
For businesses, the next step is to identify which changes actually touch their operations. Reviewing accounting procedures, transaction classifications and supporting documentation now can make the transition easier.
Further decisions and guidance will also matter for provisions that depend on additional requirements, including the threshold for the new cash-payment restriction.
Businesses that need support reviewing their UAE VAT and accounting processes can work with Arnifi for ongoing tax and compliance assistance.
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