Selling on Amazon.ae or Amazon.sa From Abroad? When You Must Register for VAT

The short answer

If you hold stock inside the country and sell it to local customers, you must register for VAT from your first sale. No turnover threshold protects a foreign seller. That is the position in both the UAE and Saudi Arabia.

If instead every order ships from abroad direct to the buyer, the answer changes, because the tax usually falls on whoever imports the goods rather than on you. The trigger in both countries is not how much you sell. It is whether anyone else is obligated to account for the tax. The UAE Federal Tax Authority and Saudi Arabia's Zakat, Tax and Customs Authority, known as ZATCA, both write the rule that way. All figures below were checked against those two authorities on 31 July 2026.

This article is general information, not tax advice. What applies to you depends on the specific facts of your business, including where your stock sits, who your buyers are, and what your marketplace agreement says. Confirm your position with the relevant authority or a qualified tax adviser before you act.

Who this affects

This is written for a seller who is non-resident, meaning a company or person with no place of residence in the country where the sale happens. If you are already licensed and resident in the UAE, the resident thresholds apply to you instead, and do you need to register for VAT in the UAE covers those.

Three situations come up again and again:

• You use Amazon fulfilment and your stock is already in the country. This is the case that triggers registration soonest, and the one most often missed.
• You ship every order from abroad direct to the customer, with nothing stored locally. Different rules, different answer.
• You do both. Then each flow is assessed on its own. Holding any sellable stock in the country is enough to bring the first case into play.

One boundary before we start. VAT registration is not a trade licence, and it is not corporate tax. Whether you need a licence to sell on the UAE marketplace at all is a separate question, covered in do you need a licence to sell on Amazon.ae.

The UAE rules

The trigger, and the condition inside it

Article 13(2) of Federal Decree-Law 8 of 2017 on Value Added Tax, as amended, requires a person with no place of residence in the UAE, or in an Implementing State meaning a Gulf state that applies the common VAT framework, to register for tax if he makes supplies of goods or services and where no other person is obligated to pay the due tax on those supplies in the State. That second half is the whole game. The obligation is conditional, not automatic.

There is no turnover test inside that clause. The Federal Tax Authority's E-Commerce VAT Guide, published in August 2020, states plainly that for non-resident suppliers the registration threshold is, in effect, nil. The FTA's VAT registration page separately states that the AED 375,000 mandatory threshold is not applicable to foreign businesses. The AED 187,500 voluntary threshold is likewise a resident rule, and the same guide confirms that a non-resident cannot register voluntarily on the basis of taxable expenses.

Stock held in the UAE, sold to UAE customers

Here the place of supply, meaning the country where the sale is treated as happening for tax purposes, is the UAE. So it is a local supply. The only way the tax moves off you is the reverse charge, the mechanism that makes the buyer account for the tax instead of the seller, and the FTA E-Commerce VAT Guide of August 2020 sets three conditions for it: the supplier has no place of residence in the UAE, the supplier does not charge VAT, and the recipient is a taxable person with a place of residence in the UAE.

A retail consumer is not a taxable person. So on consumer sales, no other person is obligated, the condition in Article 13(2) is met, and you must register. The same guide adds the practical rule for anyone selling through a marketplace: if the non-resident supplier cannot establish the details needed to apply the reverse charge, such as that the recipient is registered for VAT, then the supplier should register in the UAE and account for the VAT to the FTA itself.

Goods shipped from outside the UAE direct to the customer

Different answer. The same guide states that where a supply of goods involves the goods being transferred to the recipient outside of the UAE, the place of supply is outside the UAE, even if the goods are then imported into the UAE, and that UAE VAT does not apply to that supply. Import VAT then falls on whoever is named as importer for customs clearance.

This is why the blanket claim that selling on Amazon.ae means registering for UAE VAT is wrong as often as it is right. What decides it is where the goods are at the moment of supply.

Deadline, rate, filing

• Thirty days to apply. Article 7(2) of the VAT Executive Regulation, Cabinet Decision 52 of 2017 as amended, requires the registration application to be filed within 30 days of being required to register.
• Five percent. Article 3 of the Decree-Law imposes a standard rate of 5 percent on any supply or import. Our free VAT calculator runs the arithmetic once you know the treatment.
• Three month tax periods by default. Article 62(1) of the Executive Regulation sets the standard tax period at three calendar months, and Article 62(2) lets the FTA assign a shorter or longer period to a person or class of persons.
• The 28th day. Under Article 64, the return must be received by the Authority no later than the 28th day following the end of the tax period, and the tax must be paid by the same date.

Two UAE points worth knowing

No tax representative is required. Nothing in Federal Decree-Law 8 of 2017 or in Cabinet Decision 52 of 2017 as amended makes appointing a tax agent or fiscal representative a condition of registration for a non-resident. There is a voluntary Tax Agent Programme, and many foreign sellers use an agent by choice, but it is not a legal gate. This is a real difference from Saudi Arabia, and treating the two markets as if they worked the same way is a costly assumption.

The UAE has no marketplace deemed supplier rule for goods. There is no equivalent of the European Union or United Kingdom rule that makes the platform liable for the seller's VAT. The UAE applies ordinary agency law: under Article 9(1) of the Decree-Law a supply through an agent acting in the name of and on behalf of a principal is a supply by the principal. The FTA E-Commerce VAT Guide applies that to marketplaces, saying that where an electronic marketplace acts as a disclosed agent, meaning the customer is told who the actual seller is, the VAT obligations remain with the principal supplier. Under Article 9(2) an undisclosed agent, meaning one selling in its own name, is treated as making a direct supply, and two supplies arise.

Which side any given platform falls on is a contract question, and the FTA guide says the starting point is to analyse the contractual arrangements between the parties. So read your seller agreement, or have it read, before you assume the platform is handling anything on your behalf.

One caveat on sourcing. The FTA E-Commerce VAT Guide is dated August 2020 and has not been reissued, while the Executive Regulation was amended by Cabinet Decision 100 of 2024 and the Decree-Law by Federal Decree-Law 16 of 2024. The statutory articles quoted above were read in the current consolidated texts published by the Ministry of Finance and still stand as at 31 July 2026.

The Saudi Arabia rules

The trigger

ZATCA's VAT Implementing Regulations, under the heading on mandatory registration of non-residents obligated to pay tax in the Kingdom, require a non-resident person who is not registered but is obligated to pay tax on supplies made or received in the Kingdom to apply for registration within thirty days of the first supply on which that person was obligated to pay tax. Registration then takes effect from the date of that first supply.

The structure is the same as the UAE. No threshold applies to a non-resident: the SAR 375,000 mandatory and SAR 187,500 optional thresholds are expressed in the Regulations by reference to every resident person in the Kingdom. And the trigger again turns on whether the reverse charge shifts the liability. The Regulations provide that where a taxable customer is obligated to pay tax on a supply received from a non-resident supplier, the tax is paid by way of the reverse charge mechanism. A retail consumer is not a taxable customer, so on consumer sales of goods already inside Saudi Arabia the non-resident seller is liable and must register.

Rate, tax periods, deadlines

• Fifteen percent. ZATCA publishes the standard VAT rate at 15 percent.
• Monthly above SAR 40,000,000. The Regulations set the tax period at one month where the annual value of taxable supplies exceeds SAR 40,000,000 during the previous twelve months, and at three months for all other taxpayers. A taxpayer below the threshold may apply to file monthly.
• The last day of the following month. The return must be filed, and the tax paid, no later than the last day of the month following the end of the tax period.
• Weekends do not extend anything. The Regulations state that returns and payments must be made on or before the prescribed date whether that date is a working day or a non-working day.

The tax representative question

Handle this one carefully, because ZATCA's own two sources are not perfectly aligned. ZATCA's published page on tax agents and representatives states that all non-resident taxable persons must have one tax representative, that the representative will be jointly liable for payment of tax due by the taxable person until ZATCA confirms it has ceased to act, and that a representative who is not a member of the Saudi Organization for Certified Public Accountants, known as SOCPA, and is not a law firm must be resident in the Kingdom and commercially active for at least five years. The VAT Implementing Regulations text, however, uses the wording that a non-resident taxable person may appoint a tax representative residing in the Kingdom, and caps that joint liability at double the average quarterly value of the taxable person's output tax.

The practical reading: plan on dealing with ZATCA through an approved representative resident in the Kingdom, understand that the representative carries joint liability, and confirm the exact scope of the requirement with ZATCA for your own case. Do not treat the wording may appoint as permission to skip the step.

The security deposit almost nobody mentions

The Implementing Regulations state that all non-resident taxpayers must provide a security as a precondition of VAT registration, under the article governing securities, and that ZATCA sets the minimum and maximum value of that security at its discretion. A cash security or bank guarantee must be issued in writing.

No published amount or formula was found, so no number appears here. Ask ZATCA or your representative what applies to your case, and build it into your working capital before you commit to a Saudi launch date.

E-invoicing does not reach you, until it does

ZATCA's Phase One e-invoicing FAQ states that e-invoicing, known as Fatoora, applies to all persons subject to VAT and to any other parties issuing tax invoices on behalf of suppliers subject to VAT, and that non-resident taxable persons for VAT purposes are excluded. Phase One, generation, has been enforceable since 4 December 2021, and Phase Two, integration, since 1 January 2023, rolled out to taxpayers in waves.

That exclusion is a real advantage, and it has a second half that matters for planning. The moment you set up a resident Saudi entity instead of selling as a foreign company, the exclusion ends and e-invoicing applies in full. If a Saudi entity is on your roadmap, price that work in.

Marketplace rules in the Kingdom

Saudi Arabia does have a deemed supplier rule, but it does not cover a non-resident selling physical goods. The Regulations presume that where electronically supplied services are supplied in the Kingdom through an online interface or portal acting as intermediary for a non-resident supplier, the operator purchases and re-supplies those services in its own name and is liable for the tax, unless the non-resident supplier is expressly named as supplier in the sale process, the contract and the invoice and the operator does not set the price, terms or delivery. Separately, ZATCA's April 2025 guideline on the November 2024 amendments states that starting from January 2026 the marketplace becomes the deemed supplier where it acts as intermediary for resident suppliers who are not VAT-registered.

Neither rule catches goods sold by a non-resident. In that case you remain the supplier, and if you are liable for the tax you must register yourself.

A sourcing caveat here too. ZATCA's consolidated English Implementing Regulations are the Eighth Edition dated 9 November 2021, and they have been amended since, including by Board of Directors Resolution 01-06-24 of 19 November 2024. ZATCA states that its English translations are for guidance and that the Arabic version prevails in case of any discrepancy. Re-check any figure against ZATCA in Arabic before you rely on it commercially.

UAE and Saudi Arabia, side by side

Same structural logic, different mechanics. The differences that cost money are the representative, the security, and the filing calendar.

Read the table as the shape of the obligation, not as a substitute for checking your own facts. Both authorities publish their current position, and both have amended these texts recently.

What you need before you apply

Here is where most articles on this subject invent a checklist. This one will not, and the reason is worth stating: no published Federal Tax Authority document list for non-resident VAT registration was found. What the EmaraTax portal asks a foreign applicant for is portal practice rather than law, and it changes. Ask the FTA, or your adviser, for the current requirement at the time you apply rather than working from a list found in a blog, including this one.

What is published, and what you can plan around:

• Saudi Arabia, the security. A security is a precondition of registration for every non-resident taxpayer, with the value set by ZATCA. Budget for it as an unknown, not as zero.
• Saudi Arabia, the representative. The registration article requires a non-resident to apply either by itself or through an approved tax representative, and requires the particulars of that representative to be listed on the application form. Appointing one takes time, so start it before the thirty day clock does.
• Corporate documents will need legalising. Whichever authority you deal with, expect your company documents to be certified in a form that country accepts.

The attestation trap that catches European and Asian sellers

The UAE is not a party to the 1961 Apostille Convention. It is not listed on the HCCH status table for that convention. An apostille alone does not make a foreign document usable in the UAE. The full consular chain still applies, in this order:

1. The notary or issuing authority in the country of origin certifies the document.
2. The foreign ministry of that country legalises it. The UAE Ministry of Foreign Affairs states that a document must be legalised first by its respective foreign office.
3. The UAE embassy or consulate in that country attests it.
4. The UAE Ministry of Foreign Affairs, inside the UAE, gives the final attestation.

UAE MoFA requires the original document in Arabic or English, or accompanied by a legally certified translation. Its published attestation fees at the time of writing are AED 150 per document for personal status documents and AED 2,000 per document for commercial documents, with AED 300 where its own attestation and the UAE embassy attestation in the destination country are taken together. MoFA also warns that a commercial contract may be counted as more than one document depending on its content, so treat those figures as indicative and expect typing centre or service provider charges on top.

Saudi Arabia is different on this point. It has been a Contracting Party to the Apostille Convention since 7 December 2022. Even so, do not assume an apostille clears every Saudi authority: the Ministry of Investment's own 2026 investor guide still asks for corporate documents authenticated by the Saudi embassy. Confirm the accepted form with the authority that will receive the document.

What happens if you do not register

Late registration does not buy you time. It moves the cost.

In the UAE, Article 7(6) of the Executive Regulation provides that the FTA registers a non-resident with effect from the date on which he started making supplies in the State, whether or not he notified them of the liability to register. Article 7(7) then makes a late registrant liable to account for and pay the due tax on all taxable supplies and imports made before registering. In other words the tax was always due, and you will now pay it out of margin you have already banked, on sales priced as if no VAT applied.

On top of that sits an administrative penalty. The current published penalty table, Cabinet Decision 40 of 2017 and its amendments as published by the FTA in November 2025, sets the penalty for failure to submit a registration application within the timeframe specified in the tax law at AED 10,000. If you have read AED 20,000 somewhere, that figure is out of date.

In Saudi Arabia, the same commercial logic applies through the effective date: registration runs from the date of your first taxable supply, so the liability accrues from that date regardless of when you get around to applying. No penalty figure is quoted here because none was verified from ZATCA for this article. Ask ZATCA or your representative for the current position rather than relying on a number circulating online.

One more separation worth making, because it is the classic error in this space. VAT registration and corporate tax registration are different questions with different triggers. A foreign company can have a UAE VAT obligation and no UAE corporate tax registration obligation. Corporate tax registration under Article 51 of Federal Decree-Law 47 of 2022 turns on residence, on a permanent establishment in the UAE, or on a nexus in the UAE. Whether inventory in a UAE fulfilment centre creates a permanent establishment is fact-specific and depends on your arrangements and on any applicable double tax treaty, so it is a question for the FTA or a tax adviser, not for a general article.

The next step

Five things, in order, before your first shipment lands.

1. Write down where your stock will sit at the moment each sale completes. That single fact drives everything above.
2. Read your marketplace seller agreement, or have it read, on the question of whether the platform acts as a disclosed or undisclosed agent. The FTA says the contract is the starting point, so do not assume the platform accounts for the tax.
3. Put the thirty day clock in writing against your planned first sale date in each country. It runs from the supply, not from the day you notice.
4. For Saudi Arabia, start the representative and the security early. Both are gates, and neither is quick.
5. Confirm the current requirement with the authority before you file. Both texts have been amended recently, and portal practice moves faster than published guides.

Entityz has established more than 500 businesses and keeps 95 percent of its clients, with 12 months of post-setup support after the licence is issued. If the answer above points to registration, or to setting up locally instead of selling as a foreign company, talk to us and we will map the sequence against your own flow of goods before you commit to anything.

General information, not tax advice. Every rate, threshold and deadline above was checked on 31 July 2026 against the UAE Federal Tax Authority and its published legislation, and against Saudi Arabia's Zakat, Tax and Customs Authority. Laws and published guidance change, and your obligation depends on the specific facts of your business. Confirm your position with the relevant authority or a qualified tax adviser before acting.