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UAE VAT Accounting Record Keeping Requirement

Accounts and bookkeeping records maintained by taxable persons should be retained for a period of 5 years after the end of the tax period to which they relate.
However, this period is different for Capital Assets and Real Estate records.

The records pertaining to capital assets like machinery, furniture, etc. should be retained for at least 10 years from the end of the tax period to which they relate and records relating to real estate should be retained for at least 15 years from the end of the tax period to which they relate.

Article 3 “Period of Record Keeping”   of Cabinet Decision No. (36) of 2017 on the Executive Regulation of Federal Law No. (7) of 2017
on Tax Procedures states the followings

1. Every Person holding and maintaining any of the records mentioned in Article (2) of this Decision, shall keep these records in a manner that enables the Authority, or an officer authorised by the Authority, to ascertain that Person’s Tax obligations, as follows:
a. For a period of (5) years after the end of the Tax Period to which they relate in the case of a Taxable Person.
b. For a period of (5) years from the end of the calendar year in which the concerned document was created in the case of non-Taxable Persons.
c. For a period specified in the Tax Law for real estate records.
2. The Authority may, before the expiry of the period specified in paragraph (a) of Clause (1) of this Article, inform the Person to retain the records for a further period not exceeding (4) years, in cases where he is required to do so including the following:
a. If the Taxable Person’s tax obligations are subject to a dispute between him and the Authority.
b. If the Person is being subject to a Tax Audit and that Tax Audit has not yet been completed.
c. If the Authority has given notice to the Person that it intends to conduct a Tax Audit before the expiry of the period specified in Clause (1) of this Article.
3. If a Person is no longer a Taxable Person, he shall be required to comply with the provisions of paragraph (b) of Clause (1) of this Article.
4. Where a Person enters into bankruptcy proceedings, his Legal Representative is required to keep the records of that Person for 12 months from the date on which those proceedings have come to an end.
5. For the purposes of Clause (4) of this Article, should the Authority require the records to be kept for a longer period, it may take possession of them, at a time agreed with the Legal Representative responsible for the relevant bankruptcy proceedings.

It is worth noting the record keeping requirement period start after the end of tax period in which a record was created and NOT from the date of record.

For exampleA Tax Invoice for a supply issued  on 30th January 2018 relates to the tax period of January-December 2018. Hence, it should be retained until 31st December 2023.

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