Short answer: Yes, you can apply for UAE VAT registration on the strength of purchase orders and signed contracts — that is the correct evidence when you are registering on expected turnover. But if the deliverable date on the order falls in the current month, the Federal Tax Authority will often ask for tax invoices instead. The reason is simple: a supply due this month may already have taken place, which changes the basis on which you should be registering. Fastlane handles VAT registration from AED 199.
This trips up contractors, consultancies and trading companies constantly. You win a contract, the value takes you over the threshold, so you apply for VAT registration and upload the purchase order as evidence. A week later the FTA responds asking for invoices — and since the work is not finished and nothing has been invoiced, the request looks impossible to satisfy.
It is not impossible. It is a signal that the dates in your application do not line up, and understanding why makes the fix straightforward.
The basisCan you register for VAT using purchase orders instead of invoices?
Yes — and for one of the two mandatory registration limbs, it is the only evidence that can exist.
| Registration basis | Test | Natural evidence |
|---|---|---|
| Historic (retrospective) | Taxable supplies over the previous 12 months exceeded AED 375,000 | Sales invoices, financial statements, bank receipts |
| Expected (prospective) | You anticipate exceeding AED 375,000 within the next 30 days | Purchase orders, signed contracts, tender or letters of award |
| Voluntary | Supplies or taxable expenses exceed AED 187,500 | Either of the above, or expense records |
If you are registering because a contract you have just won will push you over the threshold, invoices by definition do not exist yet. The purchase order is the evidence. So why the follow-up?
The reasonWhy does the FTA come back asking for invoices?
Because the reviewer is checking one thing: does your stated basis match your documents? And a delivery date inside the current month creates an inconsistency.
You have said "I expect to make these supplies." The document says "delivery due this month." Those can both be true — but they can also mean the supply has already been performed, in which case the correct basis is historic, not expected, and there should be an invoice.
What does "date of supply" have to do with your application?
This is the concept underneath the whole issue, and most applicants have never had to think about it. The date of supply — the tax point — is when VAT becomes due on a transaction. It is fixed by the legislation, not by when you decide to raise an invoice.
Broadly, it is triggered by the earliest of several events:
- Goods being delivered or made available to the customer.
- Completion of the service being performed.
- Receipt of payment, including a deposit or advance.
- Issue of a tax invoice.
Note what is not on that list: signing a contract, or receiving a purchase order. An order is a commitment to buy. It evidences future turnover; it does not create a taxable supply on its own.
[VERIFY] Date-of-supply rules sit in Federal Decree-Law No. 8 of 2017 on VAT and its Executive Regulation (Cabinet Decision No. 52 of 2017), including the special rules for continuous supplies and periodic payments. Registration thresholds and timeframes, and the penalty for late registration, should be confirmed against tax.gov.ae — the penalty schedule was affected by Cabinet Decision No. 129 of 2025.
What if the supply already happened — are you registering late?
This is the part worth taking seriously, because the invoice request is sometimes the FTA noticing something the applicant has missed.
Genuinely prospective
The contract is signed, delivery is scheduled for a future date, nothing has been performed or paid. You are registering ahead of the threshold. The application is on time and purchase orders are the right evidence.
Actually historic
The work is substantially done, an advance has been received, or delivery has occurred. The tax point has passed. Your obligation to register may have arisen weeks or months ago — and the 30-day clock started then.
The consequence of the right-hand column is a late registration penalty, and possibly a period of supplies made while unregistered. Neither is fatal, and both are considerably cheaper to address deliberately than to have surfaced during a later review. Which is why the honest answer to an invoice request is sometimes: yes, here are the invoices, and I need to correct my registration basis.
EvidenceWhich documents should you submit with the application?
Submit a set that tells one coherent story about timing. For an expected-turnover application:
- The purchase order, contract or letter of award — showing value, scope and, critically, the delivery or performance schedule.
- A turnover declaration setting out historic supplies and expected supplies separately.
- Trade licence and, where relevant, the memorandum of association.
- Bank statements covering the recent period, evidencing that no advance has been received on the contract.
- Any invoices already raised, even if below the threshold — withholding them is what creates the inconsistency.
- A short covering note explaining the timeline in plain terms.
That last item is the one applicants skip and the one that most reliably prevents a query. Two sentences establishing that the contract was awarded on one date, delivery is scheduled for another, and no payment has been received will often pre-empt the entire exchange.
Worked exampleWhat does this look like with real numbers?
A Dubai consultancy with AED 190,000 of historic supplies over the past twelve months wins a project worth AED 480,000. It applies for registration on the expected-turnover basis.
| Scenario A — clean | Scenario B — queried | |
|---|---|---|
| Contract value | AED 480,000 | AED 480,000 |
| Purchase order date | 2 July | 2 July |
| Delivery / completion | 15 October | 28 July |
| Advance received? | No | Yes — AED 144,000 on 8 July |
| Tax point reached? | Not yet | Yes — on receipt of the advance |
| Correct basis | Expected turnover | Liability already arose |
| Likely FTA response | Approved on the order | Invoice request, basis correction |
Identical contract value, identical purchase order. The difference is entirely in two dates and one payment — and in Scenario B the applicant was already liable to register from the day the advance landed, not from the day they chose to apply.
What goes wrongWhat gets applications queried or rejected?
- Delivery date inside the current month with no invoice attached. The trigger for this entire article.
- Advances received but not disclosed. Visible on the bank statements you submitted, so not disclosing them helps nobody.
- Turnover declaration that does not reconcile to the documents uploaded alongside it.
- Purchase order with no dates on it at all. An undated order proves value but not timing, and timing is the whole question.
- Applying on expected turnover when historic supplies already crossed the threshold. The wrong limb, and usually late.
- Slow responses to queries. Applications do not stay open indefinitely.
How should you sequence registration around a live project?
- Establish the tax point before you apply. When is delivery, and has any advance been received? These two answers determine everything.
- Test both limbs. Check historic supplies over the last twelve months as well as expected. If historic already crosses, that is your basis.
- Apply within 30 days of liability arising. Not 30 days from when the paperwork was convenient.
- Upload the full evidence set, including any invoices already raised and a covering note on the timeline.
- Respond to any query within days, not weeks, and answer the timing question directly.
- Do not charge VAT before your TRN is issued — and plan contractually for how you will handle VAT on supplies made in the interim.
- Diarise your first return as soon as the TRN arrives. Returns are due 28 days after the tax period ends.
Point six is the one that catches new registrants commercially. There is often a gap between becoming liable and holding a TRN, and how that gap is handled with your customer — whether the contract allows VAT to be added later — is worth settling before you sign, not after. Our VAT filing service picks up from the TRN onwards.
Get the registration right the first time
Fastlane establishes your correct registration basis, assembles the evidence set so the dates reconcile, and handles FTA queries if they arise. VAT registration from AED 199. Already received a query on a live application? Send it over — we will tell you what it is actually asking.
+971 55 127 3479 · info@fastlanecareer.com
Related reading and services
- VAT registration — mandatory and voluntary applications from AED 199.
- VAT filing — quarterly returns from AED 199 once your TRN is issued.
- Accounting and payroll — books that make threshold monitoring automatic.
- VAT refund — recovering credit balances from the FTA.
- VAT deregistration — if supplies fall below the threshold or you cease trading.
- E-invoicing readiness — why invoice timing gets more visible from here.
VAT Registration
Basis assessment, evidence pack and submission — from AED 199.
VAT Filing
Quarterly return preparation and submission — from AED 199.
Accounting & Payroll
Monthly bookkeeping and threshold monitoring — from AED 499/month.
Corporate Tax Filing
Annual returns for mainland and free zone companies.
Frequently asked questions
Yes. Where you are registering on the basis of expected rather than historic turnover, purchase orders, signed contracts, tender awards and letters of award are the natural supporting evidence — invoices do not yet exist for supplies not yet made. The difficulty arises only when the dates on those documents suggest the supply has in fact already taken place.
Because the reviewer is testing whether your registration basis matches your documents. If a purchase order shows the deliverable falling in the current month, the supply may already have been made, which means a tax point has been triggered and an invoice should exist. The request for invoices is a consistency check, not an obstacle.
The date of supply is the point at which VAT becomes due on a transaction, determined by rules in the VAT legislation rather than by when you choose to invoice. It can be triggered by delivery, by completion of a service, by issuing an invoice, or by receiving payment — whichever comes first. It matters because it determines when the supply counts towards your registration threshold.
No. A purchase order is an order — a commitment to buy. It evidences expected future turnover but does not by itself trigger a date of supply. What triggers it is delivery, performance, invoicing or payment. This is precisely why a purchase order dated for delivery this month invites a follow-up question.
Then you may be registering on the wrong basis, and possibly late. If completed supplies over the preceding twelve months already exceed the mandatory threshold, the obligation to register arose historically rather than prospectively, and registration is due within a set period of that obligation arising. Late registration carries a penalty, so establish which limb applies before submitting.
The application must be submitted within 30 days of becoming liable to register. That clock starts when the obligation arises — when historic taxable supplies cross the mandatory threshold, or when you anticipate crossing it within the next 30 days — not when you get round to preparing the paperwork.
Yes. Voluntary registration is available at a lower threshold, tested against either taxable supplies or taxable expenses. It is commonly used by businesses in a start-up or pre-revenue phase that are incurring recoverable input VAT, and by suppliers whose customers expect a TRN before awarding work.
Where the application is complete and the evidence is internally consistent, approval is typically quick. Where the FTA raises a query, the clock effectively restarts on the response and the delay is driven by how fast you can produce the additional documents. The single biggest determinant of speed is whether the first submission was consistent.
Fastlane Tax Team
FTA-Registered Tax Agent · MoE-Approved Auditor · Dubai
This article was prepared by the VAT team at Fastlane Management Consultancy, a Dubai-based FTA-Registered Tax Agent and MoE-Approved audit firm. We handle VAT registration applications, threshold assessments and FTA correspondence for contractors, consultancies and trading companies across the UAE, including applications made on expected-turnover evidence.