GTL Summary:

Cabinet Decision No. 52 of 2017 provides the Executive Regulations for the UAE VAT Law. Article 12 of this Decision details the legal effects of registering related persons as a VAT Tax Group. It establishes that the representative member acts on behalf of all members for all VAT purposes. Consequently, any business, supplies, imports, output tax, or input tax of a group member is deemed to be that of the representative member. Supplies between group members may be disregarded. Critically, the Decision specifies that all members are jointly and severally liable for any payable tax.

Document Type: ERS - Executive Regulations
Law: VAT (FDL No 8 of 2017, as amended)
Decision Number: 52-article-12
Year: 2017
Country: 🇦🇪 UAE
Official Name: Article 12 - Effect of Tax Group Registration
Last updated at: 2025-12-26 14:13:51 UTC

Part 3 - Registration

Article 12 - Effect of Tax Group Registration

  1. The registration of persons as a tax group shall result in the following:

    1. Any business practiced by any member of the tax group shall be deemed to be practiced by the representative member and not by any other member of such tax group.

    2. Any supplies made by a member of the tax group to another member of the same tax group may be disregarded.

    3. Any supply, whether or not taxable, made by a member of the tax group shall be deemed to be made by the representative member.

    4. Any import of relevant goods or relevant services made by a member of the tax group shall be deemed to be made by the representative member.

    5. Any supply of goods or services made for the benefit of a member of the tax group by a person who is not a member of the tax group shall be deemed a supply to the representative member.

    6. Any output tax charged by a member of the tax group shall be deemed to be charged by the representative member.

    7. Any input tax incurred by a member of the tax group shall be deemed to be incurred by the representative member.

  2. For the purposes of Clause (1) of this Article, all members of the tax group shall be personally and jointly liable for any payable taxes of the representative member.

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