01
Document overview
An independent explanation of the FTA clarification on e-invoicing, reverse charge, input recovery, invoices, the five-year excess-credit claim limit and supply-chain evasion risk.
- New Article 54bis on supply-chain risk.
- Five-year excess-credit claim limit.
- Specific e-invoicing and self-invoice rules.
02
Scope and exclusions
Applies to
Taxable persons and advisers applying Federal Decree-Laws 16/2024 and 16/2025 to the VAT Law, including new documentation and supply-chain controls.
Limitations and exclusions
Does not replace the law, Executive Regulation or an individual FTA clarification; VATP044 and VATP045 remain separate materials.
05
Official primary source
FTA Public Clarification VATP046 · 4 September 2026
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