The evidence that makes an export zero-rated

Zero-rated and exempt are not neighbours

Both show no VAT on the invoice. That is where the similarity ends.

A zero-rated supply is a taxable supply at a rate of 0%. It counts towards your registration threshold, and the input tax attributable to it is recoverable in full. An exempt supply sits outside the tax: it does not count towards the threshold, and the input tax attributable to it is not recoverable.

On the return, zero-rated supplies go in Box 4 and exempt supplies in Box 5. Report an export in Box 5 and you have told the FTA, in writing, that you cannot recover the input tax you have just recovered. It is a two-keystroke error with a real number attached.

Get the classification right first. Then worry about proving it.

What Article 30 now names

Before November 2024 the regulation asked for "official and commercial evidence" without settling what those words covered. Exporters kept what their freight forwarder happened to send, and audits turned into arguments about whether it was enough.

Cabinet Decision No. 100 of 2024, effective 15 November 2024, replaced the vagueness with named combinations. To zero-rate a direct export of goods you retain one of the following:

• a customs declaration together with commercial evidence proving the export;
• a bill of lading together with official evidence proving the export; or
• a customs declaration proving the suspension of customs duties, where the goods go into a customs suspension regime.

The definitions were tightened at the same time. Commercial evidence is a document issued by a transport company or agent proving the goods actually departed the UAE: an air waybill, a sea waybill, a land waybill. Official evidence is an export certificate or clearance certificate issued by customs, or documentation from the destination country proving the goods entered it.

And where commercial evidence cannot be obtained at all, the amendment introduced a shipping certificate from the transport company as an equivalent. That is a genuine relief for exporters who ship on terms where the paperwork ends up with somebody else.

Ninety days, and what happens on day 91

The evidence is only half the test. The goods have to move.

For a direct export, the goods must be physically exported to a place outside the implementing states, or placed into a customs suspension regime, within 90 days of the date of supply. For an indirect export, where the overseas customer arranges collection, the same 90 days applies under an arrangement agreed at or before the date of supply, and the supplier has to obtain the export documents from that customer.

Miss the 90 days and the supply is standard-rated. Not "probably fine because it left eventually". The Authority does have discretion to extend the period where circumstances beyond the supplier's control prevented the export, but that is a concession to ask for, not a position to assume.

The practical consequence is a diary, not a legal argument. If you invoice on the date of supply and the container has not sailed by day 60, somebody should already be asking why.

Indirect exports are where the risk actually lives

A direct export is comparatively safe. You arranged the transport, so you hold the transport document.

An indirect export is the one where the overseas customer, or their agent, collects the goods in the UAE and takes them out. The supply can still be zero-rated, but you are now depending on somebody else to send you evidence after they have already been paid and after the relationship has moved on.

Two extra conditions apply that people forget. The arrangement has to be agreed at or before the date of supply, and the goods must not be altered or used between the sale and the export.

The mistake we see most: an indirect export zero-rated on the strength of a delivery note signed at the warehouse door. That proves the goods left your premises. It does not prove they left the country, and those are very different claims.

Services follow a different, narrower test

Exporting a service is not the same exercise, and it got harder in November 2024.

Article 31 already required, broadly, that the recipient has no place of residence in an implementing state and is outside the UAE at the time the service is performed. "Outside the State" carries its own gloss: a person present in the UAE for less than a month whose presence is not effectively connected with the supply is still treated as outside it.

Cabinet Decision No. 100 of 2024 added a further condition. The service must not be one treated as performed in the UAE or in a designated zone under the special place-of-supply rules. Where those rules put the place of supply here, the zero rate is no longer available, and that has been the position since 15 November 2024.

In plain terms: services connected with UAE real estate, services physically performed here, restaurant and catering, cultural and sporting events, and certain transport-related services do not become zero-rated just because the invoice is addressed abroad.

What a defensible export file looks like

A file earns its keep when somebody who was not there can reconstruct the transaction two years later.

Per shipment, keep: the tax invoice; the customs declaration; the transport document, meaning air waybill, sea waybill, bill of lading or land waybill; the packing list; proof of payment; and, for indirect exports, the written arrangement with the overseas customer plus whatever evidence they returned.

Then add the two things almost nobody keeps, and which turn a pile of documents into a file: a reference on each document tying it to the invoice number, and a note of the date of supply next to the date of departure so the 90 days can be read at a glance.

Do it per shipment, at the time. Reconstructing eighteen months of export evidence during an audit is the most expensive filing work there is, and it is usually charged by the hour.

Designated zones are not exports

This is the confusion that produces the largest single adjustments we see, so it is worth separating cleanly.

A designated zone is a fenced area listed by Cabinet Decision and subject to customs control. For goods, and only in defined circumstances, it is treated as outside the UAE. That treatment is conditional: it depends on the zone meeting the control requirements and on what actually happens to the goods.

Three things follow that people get wrong.

Moving goods into a designated zone is not the same transaction as exporting them, and it does not attract the Article 30 evidence rules. If you have been filing zone movements as exports with waybills attached, the classification is wrong even where the tax outcome happens to land in the same place.

Goods consumed inside a designated zone are generally treated as supplied in the UAE. A contractor eating through materials on a site inside a zone is not making a zone-to-zone movement.

Services are the sharpest trap. The designated zone treatment is about goods. A service supplied in a designated zone is generally treated as supplied in the UAE, so an agency invoicing a client in a free zone is normally making a domestic standard-rated supply, whatever the client believes.

If a material part of your revenue runs through a designated zone, the treatment is worth confirming in writing rather than inheriting from whoever set up the invoice template.

A quick self-test

Take your three largest zero-rated sales from last quarter and answer four questions about each.

1. Which of the named evidence combinations do you actually hold? Name the documents.
2. How many days elapsed between the date of supply and the date the goods left?
3. If it was an indirect export, where is the arrangement agreed at or before the date of supply?
4. Did the sale land in Box 4 rather than Box 5?

If any of the four takes more than ten minutes to answer, the problem is not the law. It is that the evidence is scattered across an inbox, and an auditor will reach that conclusion faster than you would like.