Check Your VAT Before the Q3 Return

• 14 September, 2026
• By Safwan, Managing Partner
• Tax Compliance

Last reviewed 14 September 2026 by the Exiloz tax team against the UAE legislation in force on that date. Tax law moves — confirm any figure against tax.gov.ae before you act on it.

A clean trial balance does not prove a clean VAT return

The Q3 VAT return can look tidy and still be wrong. A credit note may sit in email, an import may be missing from the reverse-charge work, or input tax may be claimed from a supplier file nobody has checked. For a standard quarterly period ending 30 September 2026, the FTA deadline works out to 28 October 2026, subject to the period and due date shown in EmaraTax. A VAT health check gives you time to find the gap while the source documents are still easy to retrieve. If you would rather not handle this in house, this is what our vat health check support covers.

A health check is a short control review before submission. It is not a second bookkeeping exercise. The purpose is to compare the return to the records that created it, then decide what must be corrected before the filing window closes.

Q3 starts with the tax period, not the filing button

The FTA’s VAT return filing guidance says a registered business must file and pay within 28 days from the end of its tax period. If your assigned period runs from 1 July to 30 September, counting 28 days gives 28 October 2026. Check the period and deadline in EmaraTax first. Some businesses have a different cycle.

The deadline is the outside edge of the work. Your internal date should be earlier, so there is room to trace an invoice, ask for a credit note, or separate a genuine error from a posting problem. The existing VAT filing guide for Dubai explains the return process. This article deals with the checks that make the number defensible.

Start with a VAT control file you can actually trace

Pull the source pack before opening the VAT201 form. Keep the sales ledger, purchase ledger, credit notes, debit notes, import records, reverse-charge workings, bank or card summaries, and the general ledger VAT accounts together.

Add the prior return and any corrections carried into this period.

1. Export the sales and purchase ledgers for 1 July to 30 September 2026, using the same cut-off as the return.
2. Tie the VAT control accounts to the ledger and explain every difference, including journals posted after month-end.
3. Mark transactions that need a document, a tax-code decision, a credit note or a second review.
4. Keep an owner and a due date against each open item. A list with no owner is only a list.

Rebuild output VAT from invoices and credit notes

Start with sales, because missed output tax is harder to repair after a return is filed. Compare issued invoices to the sales ledger, the receivables report and cash or card collections. Look for deposits, recurring invoices, staff charges, connected-party entries and supplies posted after the service or delivery date.

Then read the credit notes. A credit note that reduces a sale should reduce the reported value and output tax in the right period. Check that the original invoice, reason for the adjustment and customer record agree. Do not net a credit note into a monthly sales total and assume the trail is clear.

The FTA VAT Returns User Guide separates standard-rated supplies, zero-rated supplies, exempt supplies and other return fields. Review the tax code against the contract and invoice, not against the account name alone. A code called ‘services’ tells you nothing about its VAT treatment.

Input tax is where weak checks hide

Input tax needs more than a tax invoice. Match the supplier invoice to the purchase order, goods received note or service evidence, payment record and business purpose. Remove duplicates. Separate expenses that relate to exempt activity or private use. Check that an invoice is not being claimed twice because one copy arrived through email and another through the accounting system.

Imports and overseas services deserve their own line in the review. Match customs or import records to the reverse-charge working, then make sure the output and recoverable input sides agree. If a supplier invoice has no clear commercial connection to the business, park the claim until the reason and evidence are written down.

The new supplier checks begin on 1 October

FTA Decision No. 13 of 2026 was issued on 22 July, published on 20 August and takes effect on 1 October 2026. It sets measures for checking the validity and integrity of supplies before input tax is deducted. The timing matters for a Q3 file that is still being reviewed in October.

The Decision calls for supplier identity and business-place checks, a review of risk indicators, and an assessment of the transaction, payment terms, pricing and ordinary business activity. It also requires the taxable person to document the checks, keep the supporting records and maintain a policy naming the people responsible for the process.

For supplies below AED 10,000 excluding VAT, the Decision allows the measures to be disregarded. That exception does not apply where supplies from the same supplier exceed AED 100,000 over the previous 12 months or are expected to exceed it over the next 12 months. The Decision also requires a bank-account check and review of available client recommendations where supplies from a supplier exceed AED 375,000 over the previous or next 12 months.

One point remains unsettled. The official Decision gives the tests, but the material checked for this draft does not include a worked example showing how the FTA will judge an ordinary low-risk purchase when one part of the record is incomplete. Do not treat the AED 10,000 exception as a general safe harbour.

Keep a proportionate evidence trail.

A worked example catches what a trial balance misses

Example: a Dubai design firm reports AED 2,400,000 of standard-rated sales for the quarter. At the standard 5% rate, output VAT is AED 120,000. It has AED 1,000,000 of purchases carrying recoverable VAT, so input VAT is AED 50,000. The draft net payable amount is AED 120,000 minus AED 50,000, or AED 70,000.

During the check, the firm finds a July credit note reducing taxable sales by AED 100,000. At 5%, the output-tax reduction is AED 5,000. The corrected output VAT is AED 115,000 and the corrected net payable is AED 115,000 minus AED 50,000, or AED 65,000. The ledger was balanced. The return was still AED 5,000 too high until the source document was matched.

Decide the correction route before you file

A current-period posting issue can usually be fixed in the books before the return is submitted. A mistake in a previous return needs a separate decision. The FTA Voluntary Disclosure User Guide says an underpayment of no more than AED 10,000 can be corrected in the current return if the conditions for correction are met. An underpayment above AED 10,000 requires a Voluntary Disclosure.

Make that decision before the Q3 return is filed. Set out the affected period, the original amount, the corrected amount, the tax difference and the document trail. If the issue is a missing invoice or a bad code rather than a tax difference, record the fix and the reason. Do not use a Voluntary Disclosure as a substitute for a clean review.

The current penalties make timing part of the review

The amended Cabinet Decision No. 129 of 2025 applies from 14 April 2026. It replaced the older late-payment calculation. The review should therefore ask two separate questions: is the return correct, and can the payable amount be settled by the due date?

The mistake we see most is trusting totals without evidence

The mistake we see most is a manager approving the VAT return because the sales total agrees to the trial balance. That checks arithmetic, not treatment. The missing piece is usually a source document: a credit note, import entry, supplier invoice, contract, payment record or explanation for a mixed-use expense.

Keep the reconciliation and its evidence with the tax records. The FTA says VAT invoices issued and received must be retained for at least 5 years. A readable folder that ties each material adjustment to a source is more useful than a large export nobody can follow. The existing UAE tax records guide covers the retention point in more detail.

Do not leave the Q3 file until filing day

A practical sequence for this quarter is simple. Close the July to September ledgers, reconcile output VAT, reconcile input VAT, review imports and credit notes, then decide any correction route. After that, someone who did not prepare the return should read the exceptions and sign off the open items.

1. Confirm the tax period and EmaraTax deadline shown for the TRN.
2. Finish the sales, purchase, import and VAT-control reconciliations.
3. Test input claims against invoices, business purpose and supplier evidence.
4. Prepare any current-return correction or Voluntary Disclosure before submission.
5. Submit and settle by the due date, then archive the signed reconciliation pack.

If the exception list is growing, get a second review while there is still time to obtain documents. Exiloz can provide VAT health check support for the reconciliation, correction list and Q3 filing handover.

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