Invoicing a customer abroad: what the new guidelines say

Version 2.0 of the Ministry of Finance's Electronic Invoicing Guidelines, dated 26 October 2026, adds an appendix on a question many exporters and service firms have been asking: how do you issue an electronic invoice to a customer who is outside the UAE and not part of the UAE e-invoicing framework?

The guide's answer, following the PINT AE specification:

• The buyer identifier is the customer's foreign tax identification number or an equivalent identifier, where one is available, taken from the ISO/IEC 6523 list.

• The buyer VAT identifier is filled only if the buyer has a VAT identifier that applies to the transaction. Otherwise it is left empty.

• The buyer electronic address is the predefined value 9900000098, which marks a buyer that is not subject to the UAE framework and has no participant identifier.

• The transaction type is set to export (code 00000001) only where the transaction actually meets the conditions for an export under the e-invoicing specifications. A customer being abroad is not, on its own, enough. A second predefined address, 9900000099, is for exports where the receiver is not registered on Peppol.

The guide also clears up the two invoice type codes. Code 380 is for UAE tax invoices where VAT applies. Code 480, out of scope of VAT, is only for invoices that relate exclusively to supplies outside the scope of VAT. It is not for exempt or zero-rated supplies, which stay within the VAT framework and are shown through the tax treatment fields instead. The choice depends on the tax treatment of the invoice, not on whether the seller is VAT-registered or where it is established.

One scenario is spelt out. Goods supplied from a place outside the UAE directly to another place outside the UAE, without entering the country, are classified as out of scope. The guide says this applies to that scenario only and should not be read as covering every transaction outside the scope of UAE VAT.

For a UAE business, the practical step is to check that the customer records in your accounting system hold a foreign tax number for each overseas customer, and that whoever sets up your invoice templates understands that a zero-rated export is still a tax invoice, not an out-of-scope one.