
VAT · Dubai, UAE
Since 1 January 2023, the services of a natural person acting as a member of a board of directors (for a government entity or private company) are not treated as a supply of services, and are therefore outside the scope of UAE VAT. So an individual board director does not charge VAT on directorship fees and generally need not register for that income. The exception: where a person is delegated by a business to sit on a board in the business’s name, it remains a taxable B2B supply. This came in through Cabinet Decision No. 99 of 2022, clarified in VATP031.
Plenty of independent directors in Dubai are still charging VAT they should not, or worrying about registering when they no longer need to. The rule changed in 2023 and is clear once you know it. Here it is.
The out-of-scope treatment is for a natural person acting as a director. If instead a company is engaged to provide directorship services, or a business delegates one of its people to sit on a board in the business’s name and invoices for it, that is a taxable B2B supply of services at 5%. The question is always: is the director acting personally, or is a business supplying the service? In practice, the mistake we correct most is the harmless-looking one. A director keeps adding 5% out of habit after January 2023, and ends up sitting on months of VAT that was never his to charge.
The out-of-scope rule looks at the nature of the service (a natural person's directorship), so it can apply to non-resident individuals acting as directors too, though cross-border and reverse-charge questions should be checked case by case. And if the same person provides other services (consultancy, management), those are assessed for VAT on their own merits. Only the directorship element is out of scope.
Dr K sits on two boards. For a Dubai private company she is appointed personally and receives AED 200,000 a year in director fees. Since 1 January 2023 that is not a supply of services, so no VAT is charged and the AED 200,000 does not count toward her registration threshold. Separately, her consultancy company is engaged by a bank, and the firm delegates her to the bank’s board for AED 300,000. That is a taxable B2B supply at 5% (AED 15,000 output VAT), because the supplier is a legal person, not the natural person herself. Same individual, same boardroom skills. The VAT answer turns entirely on who is appointed.
The out-of-scope rule applies from 1 January 2023; before that, independent directors charging above-threshold fees were making taxable supplies. Fees relating to services performed up to 31 December 2022 keep their old treatment even if invoiced later. The tax-point analysis in VATP031 matters for anything that straddled the change. Directors who stayed registered after the change with no other taxable supplies should have deregistered; late deregistration carries its own administrative penalty, so fixing this history cleanly is worth a short professional review. Our steer is usually to deregister once directorship is your only activity, but not reflexively. If you expect consultancy or other taxable work within a few months, holding the registration saves re-applying, so weigh the filing burden against the likely restart.
The change was made by Cabinet Decision No. 99 of 2022, amending Article 3 of the VAT Executive Regulation (Cabinet Decision No. 52 of 2017) with effect from 1 January 2023, and is explained in FTA Public Clarification VATP031: the functions of a board member performed by a natural person are not a supply of services. Delegated corporate directorships stay taxable at 5%. If directorship was your only registered activity, our VAT deregistration service closes the registration cleanly, and our VAT consultants handle the straddling-period analysis.
Exiloz confirms whether your directorship fees are out of scope, handles any deregistration, and separates taxable services correctly. See our VAT consultancy or talk to a Dubai consultant.
No, not for a natural person acting as a board member. Since 1 January 2023, an individual director's board services are outside the scope of UAE VAT, so no VAT is charged on the directorship fees.
A natural person's board-director services are out of scope. But where a company provides directorship services, or a business delegates a person to a board in its name, that is a taxable B2B supply at 5%.
Generally not for directorship income alone, since it is out of scope. If the person makes other taxable supplies above the threshold, registration may still be required for those.
The rule looks at the nature of the service — a natural person's directorship — so it can apply to non-resident individuals acting as directors, but cross-border and reverse-charge points should be checked case by case.
Yes. Where a company supplies directorship services, or delegates one of its people to a board and invoices for it, that is a taxable supply of services at 5%.
Yes. We confirm what is out of scope, handle deregistration if needed, and correct any wrongly-charged VAT.
Not since 1 January 2023 for natural-person directorships — out-of-scope income is excluded from the AED 375,000 test. A delegated corporate directorship remains taxable and does count for the supplying company.
Incorrectly charged VAT has to be corrected — credit notes to the company, adjustment of the returns concerned, and where relevant a voluntary disclosure. A short review establishes the cheapest compliant fix.
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