A blank invoice and a separate blank receipt side by side on a light wooden desk beside a calculator and a pen, in a Dubai office, soft daylight.

Last reviewed 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.

Two VAT treatments on one invoice

A PRO invoice for a visa usually mixes the agent's own service fee with government fees. They do not carry the same VAT, and treating them alike is a common error. The difference decides how much VAT the client pays and what it can later recover. Sound VAT consultancy in Dubai sorts this out before the first invoice goes out.

This guide covers both sides of the transaction: the PRO provider issuing the invoice and the company paying it. It explains which government fees actually carry VAT, and why the PRO fee always does. It then applies the Federal Tax Authority's disbursement and reimbursement tests to recharged fees. It ends with how the paying company should record each invoice line.

Do government visa fees carry VAT?

Article 10 of the VAT Law treats a government agency as making a business supply only in two cases. Its activity must be non-sovereign, or it must compete with the private sector. A Cabinet resolution names which government activities count as sovereign.

Do not assume either way, because fee schedules differ by service. GDRFA Dubai's own page for a family entry permit lists a AED 200 visa fee plus 5% VAT. Read each receipt: VAT on a proper tax invoice may be recoverable, while no VAT means nothing to claim.

Quick Answer

Some UAE government fees carry VAT and some do not. GDRFA Dubai lists 5% VAT on some visa fees, and only a valid tax invoice supports an input tax claim.

Is the PRO agent's own fee subject to VAT?

Yes, when the PRO provider is registered for VAT, its service fee is an ordinary standard-rated supply. The standard rate is 5%, charged on the service the agent performs for the client. That covers form filling, typing, attending centres and chasing approvals.

The fee must appear on a tax invoice showing the supplier's name, address and tax registration number. Article 59 of the VAT Executive Regulation lists every particular a tax invoice requires. An invoice missing the registration number cannot support an input tax claim, however genuine the service was.

Quick Answer

In the UAE, a registered PRO's fee carries 5% VAT. The client needs a proper tax invoice showing the supplier's tax registration number before it can recover that input VAT.

When is a recharged government fee a disbursement?

Public Clarification VATP013 defines a disbursement as a payment made on behalf of another person. It is not a supply, so no VAT applies to it. Each of its tests should be met on the real facts.

The client must receive the service and be responsible for paying for it. It must hold the receipt in its own name and have authorised the agent to pay. The fee must be additional to the agent's own service, shown separately on the invoice, and recovered at the exact amount, with no mark-up.

Quick Answer

Under UAE VAT, a properly disbursed government fee sits outside VAT. It must be paid on the client's behalf, in its name and at cost, then shown on the invoice.

When does a recharge become a reimbursement?

VATP013 treats a recovery as a reimbursement when the agent acted as principal, not as agent. That means it contracted in its own name, received the service and owed the payment itself. A reimbursement then follows the same VAT treatment as the main supply.

Take an illustrative PRO invoice with an AED 500 service fee and AED 3,000 of government fees. As a disbursement, VAT is due only on the AED 500, which comes to AED 25. As a reimbursement, VAT falls on AED 3,500, which comes to AED 175.

Quick Answer

Under UAE VAT, an agent acting as principal makes a reimbursement. VAT then applies to the whole recharged amount, including the government fee, at the main supply's rate, usually 5%.

How should the paying company record these costs?

Book the PRO fee as an expense, with its VAT as recoverable input tax. Book disbursed government fees at cost, against the receipt in the company's name. A common and costly mistake is claiming input tax on a fee that never carried VAT.

For Corporate Tax, both lines are normally deductible expenses under Article 28 of the Corporate Tax Law. Employee visa costs stay with the employer, because Article 6 of the labour law bars charging recruitment costs to workers. Keep each employee's visa costs traceable to their personnel record.

Quick Answer

UAE companies book the PRO fee with recoverable VAT. Disbursed government fees go in at cost, and both lines are normally deductible for Corporate Tax and remain the employer's cost.

Get Your PRO Invoices Coded Correctly

Exiloz splits disbursements from service fees and corrects input tax before your VAT return. Ask about VAT consultancy in Dubai.

Frequently Asked Questions

Do I pay VAT on visa fees paid to the immigration authority?

It depends on the specific fee, so never assume. GDRFA Dubai's published schedule for a family entry permit lists AED 200 plus 5% VAT, so check every receipt line carefully.


Does a PRO company charge VAT on its service fee?

Yes, provided the PRO company is registered for VAT. Its own service fee then carries 5% VAT, and the client can usually recover that VAT with a valid tax invoice.


What is the difference between a disbursement and a reimbursement?

One is outside VAT and one is not. A disbursement is paid on the client's behalf and falls outside VAT, while a reimbursement simply follows the main supply's VAT treatment.


Can a PRO agent add a mark-up to government fees?

It can, but the disbursement treatment is then lost. Under the clarification VATP013, VAT would apply to the whole recharged amount at the main supply's rate, which is usually 5%.


Whose name must appear on the government receipt?

For a disbursement, it should be the client's name. A receipt in the agent's own name usually points to a reimbursement instead, and VAT then applies to the whole recharge.


Can we recover input VAT on disbursed government fees?

Only where the receipt is a proper tax invoice. It must be in your company's name and show VAT, as in VATP013's example where the client recovers that VAT itself.


Do these rules apply when our own staff do the PRO work?

No, not when the PRO work stays in-house. An in-house PRO paying fees for its own employer's staff creates no recharge, so the company records them as ordinary staff costs.


Can we recharge visa costs to the employee?

No, the employer must carry those visa costs. Article 6 of the labour law bars charging recruitment and employment costs to workers, although family extras can be agreed in writing.


Are visa and PRO costs deductible for Corporate Tax?

Normally yes, because they are genuine business costs. Article 28 allows costs incurred wholly and exclusively for the business, so keep tax invoices and government receipts with each employee's file.


Can Exiloz review our PRO invoices?

Yes, line by line, before each VAT return. Exiloz splits disbursements from service fees on every PRO and visa invoice, and corrects any past input tax that was wrongly claimed.

Main Takeaways

Some government fees carry no VAT, but GDRFA Dubai lists 5% VAT on certain visa fees. A VAT-registered PRO provider charges 5% VAT on its own separate service fee. Recharged government fees escape VAT only when they pass every disbursement test in the FTA's VATP013. Otherwise the recharge is a reimbursement, and VAT applies to the whole amount at 5%.

Split Every PRO Invoice Into Its Parts

A PRO invoice looks simple until it reaches the VAT return. Two different VAT treatments usually sit on the same page. The agent's fee carries VAT, while properly disbursed government fees carry only the authority's own VAT, if any. Getting that split wrong either overpays VAT to the supplier or claims input tax that never existed in the first place.

Ask your PRO provider to show government fees separately, at cost, with receipts in your company's name. Our guide to input tax due diligence covers the checks the FTA expects before you claim. Keep each government receipt filed with the matching tax invoice. Exiloz can review PRO invoices, correct past claims and set up clean ledger coding for future ones.

Sources & References

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