When is a building treated as complete for UAE VAT?

Last updated

On the date it is certified complete by an appropriately qualified party. Section 12.5 of the FTA real estate guide adds that if the building is occupied before certification, the date of occupation is the completion date. The completion date starts the three-year window for zero-rating the first residential supply.

Partly completed buildings

Selling a partly completed commercial building before completion is standard-rated unless it qualifies as a transfer of a going concern. Where the building does not yet exist when the sale contract is signed, the VAT position depends on the contract, and Article 26 applies to periodic payments.

Why occupation matters on site

Early handover of floors to tenants or the client's fit-out contractor can count as occupation. That can move the completion date earlier than the certificate, which shortens the zero-rating window for a residential developer.

How SupaJack Construct records it

The project holds the completion certificate and handover dates, and quality and handover records show when areas were handed over, so both dates are on file.

Related tools and guides

See the VAT guide for contractors, the VAT calculator, the payment certificate calculator, the retention calculator, finance and VAT in SupaJack Construct, the answer on whether a payment certificate triggers VAT and the meaning of e-invoicing.

Worked example

A residential building is occupied by the developer's first tenants on 1 March and certified complete on 15 May. For VAT the completion date is 1 March, so the three-year zero-rating window for first supplies ends on 1 March three years later.

Questions people ask

Who can certify completion?

An appropriately qualified party, as the guide puts it.

Does occupation before certification count?

Yes. The earlier occupation date is used.

Is a partly built commercial building taxed?

Yes, unless it is a transfer of a going concern.

Sources

  1. FTA VAT Guide: Real Estate (VATGRE1)
  2. Federal Decree-Law No. 8 of 2017 on Value Added Tax and amendments (Federal Tax Authority)

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