E-Invoicing Reverse Charge in the UAE: PINT AE Format for Gold and Scrap Supplies

Domestic reverse-charge accounting is one of the most technically demanding areas of UAE VAT, and one of the highest-stakes once the e-invoicing mandate goes live under Ministerial Decisions 243 and 244 of 2025 and the penalty framework in Cabinet Decision 106 of 2025. UAE suppliers of investment gold, diamonds and scrap metals must issue invoices that shift the VAT accounting obligation to the registered buyer, format them correctly under PINT AE, and retain the supporting declarations that the Federal Tax Authority will inspect during any audit.

This guide explains how to issue a domestic reverse-charge invoice under PINT AE — which categories qualify, the structured fields the FTA expects, the written declarations the supplier must hold, and how the workflow differs between the gold/diamond regime and the scrap metals regime added from 14 January 2026. If you would rather have the classification, declarations and ASP validation set up for you, our e-invoicing setup support in the UAE covers the full reverse-charge workflow.

So what is domestic reverse charge?

The reverse charge mechanism in UAE VAT flips the usual flow. In a standard UAE VAT transaction, the supplier charges 5% VAT, collects it from the buyer, and remits it to the FTA. Under reverse charge VAT UAE rules, that responsibility moves the other way. Under domestic reverse charge, the supplier issues the invoice at 0 VAT, the buyer self-accounts for both the output VAT (as if they had supplied the goods to themselves) and the corresponding input VAT recovery in the same period. That is how a buyer claims reverse charge VAT in the UAE: one output entry, one matching input entry, netting to nil where recovery is full. The net VAT effect is typically nil — but both sides must report the transaction.

You will hear it called RCM far more often than its full name. The abbreviation is standard across UAE finance teams, ERP tax-code screens and ASP configuration menus, and RCM in UAE VAT means exactly this treatment — nothing narrower or wider. So if your accounting system has a tax code labelled RCM, check which regime it was set up for before you point invoices at it, because the domestic gold and scrap rules and the cross-border import rules both wear the same three letters.

Why does the mechanism exist? Two reasons. It removes the supplier’s cash-flow burden of collecting VAT on large-value transactions. And it closes a fraud channel — the FTA never has to chase a supplier for VAT they may never have collected on high-value, fast-moving goods like gold and scrap. Honestly, of the two, the anti-fraud motive is the one that drives how strictly the rules get enforced.

The two categories that dominate day-to-day UAE trading are:

• Gold, diamonds and other precious metals and stones between VAT-registered businesses, under Cabinet Decision No. 127 of 2024, which replaced the earlier, narrower gold-and-diamond regime
• Scrap metals between VAT-registered businesses from 14 January 2026, under Cabinet Decision No. 153 of 2025

They are not the whole list, though, and a supplier who assumes they are will mis-code the rest. The UAE Electronic Invoicing Guidelines set out the full set of goods to which the domestic reverse charge tax category may be applied, each with its own instrument behind it.

Two operating rules attach to that table under the Guidelines and they are easy to miss in a template build. Where the reverse charge tax category is applied, the supplier issues an electronic invoice that carries no VAT and includes a narrative specifying the reason the supply is subject to the mechanism. Separately, the type of goods subject to the reverse charge must be included as a reference on the electronic invoice. A template that emits category code AE at 0.00 but no goods reference is incomplete, and it is incomplete in a way a validation engine may not catch for you.

Cross-border imports of services and goods also operate on a reverse-charge basis, but those follow separate rules under Articles 48-49 of Federal Decree-Law No. 8 of 2017. This guide focuses on the domestic regime.

One point about those cross-border imports is worth stating early, because it saves an unnecessary integration workstream. The Guidelines confirm that the import of Concerned Goods and Concerned Services under Article 48 is not subject to any e-invoicing requirements. There is no supplier in the UAE system to issue a structured document, so the buyer’s obligation stays exactly where it was: self-account on the VAT-201 and keep the underlying import evidence. Do not build a self-billing flow to manufacture an electronic invoice for an import that the rules never asked you to produce.

How e-invoicing changes reverse charge in the UAE

E-invoicing reverse charge in the UAE is not a new tax rule — it is the same mechanism moved onto a structured, machine-readable rail. Before the mandate, a gold or scrap supplier could raise a PDF or paper invoice, write “reverse charge” somewhere on the face of it, and file it away. The classification lived in free text, and an FTA officer only saw it if they pulled the document during an audit. Under e-invoicing, that same decision has to be expressed as a coded field — category code AE at rate 0.00 — that travels through your Accredited Service Provider and reaches the buyer’s system in structured form.

Three things change in practice. First, the classification becomes visible to the FTA close to real time, not years later. Second, the buyer’s TRN is validated against the register before the invoice is accepted, so a reverse-charge sale to an unregistered buyer is stopped at source. Third, the supplier’s reverse-charge output and the buyer’s self-accounted entries can be reconciled automatically across the two feeds. The mechanism has not moved; the room for a quiet mistake has shrunk. For how the mandate is being phased in overall, see our UAE e-invoicing 2026 guide.

When reverse charge actually kicks in

Domestic reverse charge does not apply automatically to every gold or scrap supply. The conditions are strict, and our guide to VAT on gold in the UAE works through where the 5% is charged normally and where the buyer self-accounts instead.

For gold and diamond supplies (Cabinet Decision 127 of 2024):

• Both supplier and buyer must be VAT-registered in the UAE
• The buyer must intend to use the goods for resale, manufacture, or further production of gold/diamond products
• The buyer must provide a written declaration confirming VAT registration, qualifying end-use, and acknowledgement of reverse-charge treatment
• The supplier must retain the declaration in their records

For scrap metal supplies (Cabinet Decision 153 of 2025, effective 14 January 2026):

• Both supplier and buyer must be VAT-registered in the UAE
• The goods must fall within the scope of the Cabinet Decision’s scrap metals list
• The buyer’s written declaration must confirm registration and end-use
• The supplier must retain the declaration

If any condition is missed (buyer not VAT-registered, declaration not obtained, end-use does not qualify) the supply reverts to standard-rated and the supplier must charge 5% VAT. Getting this wrong is the most expensive single VAT error category in UAE SME practice.

PINT AE field map, line by line

Under PINT AE, a domestic reverse-charge invoice is identified by a specific combination of fields that the ASP’s validation engine cross-checks before transmission.

The ASP validation engine checks that the buyer TRN is active in the FTA register before it accepts category code AE. If the buyer isn’t VAT-registered, the invoice bounces. The system simply won’t let you classify a sale to a non-registered counterparty as reverse charge.

The exemption reason text is the field that earns its keep during an audit. A clear note pointing to the right Cabinet Decision saves you a lot of explaining a year later.

A Dubai gold trader bills AED 800k — what the invoice looks like

A Dubai gold trading company sells investment-grade gold bullion worth AED 800,000 to a registered jewellery manufacturer on 15 July 2026. The buyer provides the written declaration confirming VAT registration and intent to use the gold for jewellery manufacture.

Supplier’s VAT return reporting: the AED 800,000 is reported as a reverse-charge supply in the supplier’s VAT return, with no output VAT charged.

Buyer’s VAT return reporting: AED 800,000 in Box 3 (supplies received subject to reverse charge), AED 40,000 output VAT (5% of AED 800,000) and AED 40,000 input VAT in Box 10. Net VAT effect: nil.

The PINT AE invoice flows through the supplier’s ASP, reaches the buyer’s ASP, and is booked in both systems with the correct entries. The FTA sees both sides in real time and the net VAT position reconciles automatically.

Scrap metals joined the regime in 2026

The scrap metals reverse-charge regime came into effect 14 January 2026 under Cabinet Decision 153 of 2025, extending the same treatment that already governs gold VAT in Dubai to the scrap trade. So UAE scrap VAT now works like gold: it applies to a defined list of scrap metal categories supplied between VAT-registered UAE businesses.

The mechanics are identical to the gold/diamond regime: supplier invoices at 0 VAT with category code AE, buyer self-accounts. The only differences are:

• The exemption reason references Cabinet Decision 153 of 2025 rather than Cabinet Decision 127 of 2024
• The buyer’s written declaration must specifically address the scrap metals end-use
• The qualifying goods are defined by Cabinet Decision 153 of 2025 — businesses dealing in mixed scrap should map every item code to the qualifying list

For businesses that deal in both gold and scrap (or other reverse-charge categories), each transaction must be classified individually. The category code, exemption reason and buyer declaration are per-transaction, not per-customer.

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Reverse charge is per-supply, not per-customer. The same buyer can have one reverse-charge invoice and one standard-rated invoice on the same day if the end-use differs.

Does e-invoicing apply to import reverse charge in the UAE?

Import reverse charge sits outside the gold and scrap regime, and it behaves differently once e-invoicing is live. When a UAE business buys goods or services from a foreign supplier, it already self-accounts for VAT under the import reverse charge in Articles 48 and 49 of Federal Decree-Law No. 8 of 2017 — declaring the reverse-charge VAT on the import and recovering the matching input VAT where entitled. That obligation does not disappear when domestic e-invoicing switches on.

This is the ground people mean when they say UAE import VAT. On the services side there is nothing to settle at a border at all — the charge exists only as the two entries you raise against yourself. On the goods side, VAT on imported goods in the UAE runs through the customs and VAT-return mechanics that attach to your registration status, so confirm how your TRN is linked to your customs code before you assume the return will pick the import up on its own.

The practical wrinkle is that a supplier in, say, Germany or India is not on the UAE Peppol network and will not send you a PINT AE document. So there is no inbound structured invoice for your ASP to validate. Your own system still has to raise the reverse-charge entries from the foreign supplier’s commercial invoice, and — where self-billing applies — may generate a structured record on the importer’s side instead.

The rule of thumb: domestic supplies between two UAE-registered parties flow as PINT AE documents with category code AE; cross-border imports keep running on the existing self-assessment rules, with any structured record raised locally rather than received. Do not assume the e-invoicing pipe captures an import for you — that entry is still yours to book. Our UAE self-billing rules guide covers the importer-generated invoice case in more depth.

On the buyer’s side, after the file lands

Once the buyer’s accounting system receives the PINT AE invoice from their ASP and identifies the AE category code, the system must:

1. Book the supply at gross value (AED 800,000 in the example above)
2. Calculate and book output VAT at 5% (AED 40,000)
3. Calculate and book input VAT at the same 5% (AED 40,000) where the buyer is entitled to full recovery
4. Report the transaction in Box 3 of the next VAT return
5. Report the input VAT in Box 10

Modern cloud accounting systems — Zoho Books, Xero, QuickBooks, Tally, Odoo, SAP, Microsoft Dynamics 365 — handle reverse-charge entries through tax codes that automatically generate the double-sided entry. The configuration needs to be set up before the first invoice arrives; relying on manual journals at month-end creates errors.

Where the buyer is partially exempt (financial services firms, residential property landlords with mixed portfolios), the input VAT recovery may be restricted under the standard apportionment rules. The reverse-charge mechanism does not override partial exemption — it just shifts where the VAT is reported.

When the two sides don’t tie out

The FTA’s real-time data feed gives the reconciliation a clean structure. For every PINT AE invoice with category code AE issued under a supplier TRN, the same invoice should appear in the buyer TRN’s incoming feed with both an output and input VAT entry within the same period.

Where the reconciliation does not match, the cause is usually one of:

• Supplier issued reverse-charge invoice but buyer did not self-account (buyer system not configured)
• Buyer’s accounting period differs from supplier’s, creating a timing gap
• Buyer did not register for VAT, so reverse charge was inappropriate from the start
• Category code applied incorrectly to a standard-rated supply

The first two are workflow issues that ASPs can flag automatically. The third and fourth are classification errors that surface as FTA queries within one or two quarters of go-live.

What goes into the buyer’s written declaration

The written declaration the buyer provides should include, at minimum:

• Buyer’s full legal name and trade licence number
• Buyer’s TRN (and confirmation it is active)
• Statement of intent to use the goods for the qualifying end-use (resale, manufacture or further production)
• Reference to the relevant Cabinet Decision (127 of 2024 for gold/diamonds, 153 of 2025 for scrap)
• Acknowledgement that the buyer will self-account for VAT under reverse charge
• Date and authorised signature

This declaration can be a one-time blanket declaration covering all qualifying supplies from a given supplier (refreshed annually), or per-transaction. A blanket declaration is the usual choice for an established trading relationship, and a per-transaction one for occasional counterparties. Either way, the declaration must be in writing and retained for 5 years under Article 78 of FDL 8/2017.

Questions to put to every ASP shortlist

When shortlisting an Accredited Service Provider, reverse-charge handling deserves explicit testing. The questions to ask:

• Does the ASP validate buyer TRN registration status before accepting category code AE?
• Can the ASP store exemption reason references at category-code level?
• Does the ASP produce a reverse-charge reconciliation report for the supplier and Box 3/Box 10 for the buyer?
• Can the ASP flag where a customer regularly receives reverse-charge invoices without the corresponding declaration on file?
• How does the ASP handle credit notes against reverse-charge invoices — does the original AE code carry forward correctly?

Ask those questions in writing and keep the answers. Accreditation is published and maintained by the Ministry of Finance under Article 5(2) of Ministerial Decision No. 243 of 2025, so confirm any provider’s current status against that list rather than against a sales deck — and ask for reference customers in gold trading, jewellery manufacturing or scrap metals before signing.

Do reverse-charge invoices get a separate e-invoicing deadline?

No — reverse-charge supplies do not sit on their own timetable. A gold trader, refiner or scrap dealer comes into scope on the same date its general e-invoicing obligation begins under the phased UAE rollout set out in Ministerial Decisions 243 and 244 of 2025. From that date, every in-scope B2B supply the business issues — standard-rated and reverse-charge alike — has to leave as a structured PINT AE document through an Accredited Service Provider.

That carries a planning consequence worth flagging. Reverse-charge invoices are the ones most likely to hide a classification problem — a missing declaration, a lapsed buyer TRN, a mixed gold-and-scrap ledger — so they are the worst category to be cleaning up in the week before go-live. The safer order is to fix the declaration and classification debt first, well ahead of the mandate, then let the e-invoicing rail carry decisions that are already correct. Businesses that treat the deadline as a data-quality project rather than a software switch tend to reach go-live without a scramble. For how the later phases extend the obligation, see our e-invoicing phase 2 readiness guide.

If you issue these invoices regularly, work through this list

If your business issues reverse-charge invoices regularly — typical for gold traders, refiners, jewellery wholesalers, scrap metal dealers — work through this checklist before your mandatory deadline.

• Identify every customer that currently receives reverse-charge invoices
• Confirm each customer’s VAT registration is current via the FTA register
• Verify the buyer’s written declaration is on file, dated, and signed
• Refresh blanket declarations more than 12 months old
• Configure customer master records with default category code AE where appropriate
• Build the exemption reason text into the invoice template
• Pilot the new PINT AE workflow with one reverse-charge customer
• Reconcile your reverse-charge reporting for the current quarter as a baseline
• Train accounts team on the per-supply classification rule (not per-customer)
• Set up the credit-note workflow to carry forward the AE code correctly

For the underlying reverse-charge mechanism rules, see our reverse charge mechanism UAE guide. For where the category code sits in the wider PINT AE field map, see our UAE tax invoice format 2026 guide. Gold and jewellery traders should also review our gold jewellery accounting UAE guide for sector-specific considerations.

How Velmont Crest helps

For UAE businesses operating in gold, diamond or scrap metals, the e-invoicing mandate is an opportunity to fix the declaration-tracking debt that most operators have accumulated since 2018. The cleanest sequence is:

1. Run a master-data audit on every customer currently receiving reverse-charge invoices
2. Verify the written declaration is on file and current for each
3. Reclassify any past invoices where the declaration is missing or expired
4. Quantify any output VAT exposure and assess voluntary disclosure
5. Configure ASP validation rules to enforce buyer registration checks
6. Pilot the PINT AE workflow with one or two key customers before mandatory go-live

Done well, reverse-charge invoicing under PINT AE removes the manual classification burden and gives the FTA a real-time reconciliation across both parties. Done late, missing declarations and miscoded invoices compound — and because the exposure scales with the value of gold and scrap consignments rather than with a fixed fine, it compounds faster here than in most other areas of UAE VAT.

For tailored advisory on your reverse-charge invoicing setup and declaration audit ahead of the rollout, contact Velmont Crest — we work alongside your ASP selection, not against it.