Guide to VAT Reimbursement and Disbursement in the UAE
VAT Reimbursement and Disbursement in UAE

Complete Guide to VAT Reimbursement and Disbursement in the UAE

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    In commercial transactions, a person may incur expenses and then subsequently recover these expenses from another party. The VAT treatment of the amount recovered depends on whether the recovery is a "disbursement" or a "reimbursement". The difference between these, and their VAT treatments, are explained in the Public Clarification issued by Federal Tax Authority "Disbursements and Reimbursements" (VATP013).

    What is VAT Disbursement?

    Disbursement refers to the recovery of payments made on behalf of another person. Disbursement of expenses is outside the scope of VAT. This would include a payment that a business makes on behalf of a client but for which the client is later invoiced by the business.
    The following principles help determine whether the recovery of an expense from another party satisfies the conditions for being classified as a disbursement:

    The other party should be the recipient of the goods or services.

    The other party should be responsible for making the payment to the supplier.

    The other party should have received an invoice or tax invoice in its own name from the supplier.

    The other party should have authorized the payment to be made on its behalf.

    The goods or services paid for should clearly be additional to the supplies made to the other party.

    The payment should separately be shown on the invoice and recovery should be of the exact amount paid, without a mark-up.

    What is VAT Reimbursement?

    Reimbursement refers to the recovery of expenses incurred as a principal. Reimbursement of expenses falls within the scope of VAT. A reimbursement is considered to be a part of consideration for the supply and follows the same VAT treatment as the main supply.
    The following principles help determine whether the recovery of an expense from another party amounts to a reimbursement:

    The first party should have contracted for the supply of goods or services in its own name and capacity.

    The first party should have received the goods or services from the supplier.

    The supplier should have issued the invoice in the first party's name, with the first party legally obliged to make payment for it.

    In case of goods, the first party should own the goods prior to making the onward supply to the other party.

    Example 1: VAT Reimbursement

    Question 1:

    Company X entered into a contract with Company Z to provide marketing services. The contract stipulated that Company X would be eligible to reimburse the expenses from Company Z. Company X incurred the expenses in its own name and subsequently recovered the amounts from Company Z as per the terms of the contract.

    Answer: The recovery of expenses from Company Z will be a reimbursement and will follow the same VAT treatment as that of the main supply.

    Example 2: VAT Disbursement

    Question 2:

    Company X procured group medical insurance from a local insurance company and received an invoice directly from the insurance company. Company X requested Company Z to make the payment on its behalf.

    Answer: The recovery of the amount by Company Z from Company X will amount to a disbursement, and will not be subject to VAT. Company X should receive a Tax Invoice addressed to it from the insurance company, and should recover the input tax through its UAE VAT return, subject to the normal input tax recovery rules.
    The principles stated above should serve as indicators for analyzing whether an expense recovery qualifies as a reimbursement or a disbursement. However, the taxpayer should consider all relevant facts and circumstances of the transaction holistically before making a determination.

    A&A Associate provides the right guidance on VAT reimbursement, disbursement, and compliance in the UAE. To learn more, reach out to our expert VAT consultants in the UAE. Contact us today .

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